Issue Date
April 28, 2008
Audit Report Number
2008-SE-1003
TO: Randall R. Akers, ONAP Administrator, Northern Plains Office of Native
American Programs, 8API
FROM: Joan S. Hobbs, Regional Inspector General for Audit, Region X, 0AGA
SUBJECT: Salish and Kootenai Housing Authority, Pablo, Montana, Did Not Properly
Recognize and Account for Program Income from 1937 Act Housing Projects
HIGHLIGHTS
What We Audited and Why
We audited Salish and Kootenai Housing Authority (Authority) as part of our review of
the Office of Native American Programs’ guidance on calculating program income for
United States Housing Act of 1937 (1937 Act) housing projects assisted by the Native
American Housing Assistance and Self Determination Act of 1996 (NAHASDA). The
objective of the audit was 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.
What We Found
The Authority did not have adequate accounting policies and procedures for allocating
income from 1937 Act properties receiving Indian Housing Block Grant (Block Grant)
program assistance between its general fund and Block Grant programs. It failed to track
Block Grant rehabilitation or capital expenses for each property and recognize
NAHASDA revenue from substantially rehabilitated properties. It also miscalculated the
amount of program income because it included units converted to non-NAHASDA tax
credit units in its average expense level calculation. As a result, more than $184,000 in
low-rent housing receipts were inappropriately excluded from Block Grant affordable
housing funds during the period October 1, 2002, through December 31, 2006, and
should be reclassified. These conditions occurred because management created policies
and procedures for determining and administering program income that did not comply
with applicable guidance and regulations.
What We Recommend
We recommend that HUD require the Authority to (1) implement policies and procedures
to determine program income in accordance with HUD requirements; (2) update its
computation of program income, properly segregating the revenue and allowable expense
level calculation for low-income housing tax credit properties from other 1937 Act low-
rent units and reclassifying $174,054, previously withdrawn from the 1937 Act low-rent
program as nonprogram income, as Block Grant funds; (3) reduce the number of 1937
Act units capable of producing nonprogram income by the nine units that received
substantial rehabilitation or capital expenses between 2002 and 2006 using Block Grant
funds, which exceeded 40 percent of the dwelling, construction, and equipment costs, and
reclassify $10,172 as NAHASDA revenue; and (4) adjust the annual 2007 and forward
1937 Act program income calculations to include all revenue from substantially
rehabilitated units as NAHASDA revenue.
For each recommendation without a management decision, please respond and provide
status reports in accordance with HUD Handbook 2000.06, REV-3. Please furnish us
copies of any correspondence or directives issued because of the audit.
Auditee’s Response
We provided our discussion draft to the Authority and HUD’s Northern Plains Office of
Native American Programs on March 11, 2008, and held an exit conference on March 18,
2008. The Authority disagreed with our finding and recommendation to track capital
expenditures as instructed in HUD program income guidance and as defined in OMB
Circular A-87. Instead, the Authority developed their own definition of long-term
maintenance and rehabilitation which avoids attributing income to NAHASDA’s
assistance of 1937 Act units.
Also, the Authority agreed with the finding that they needed to correct the unit count used
to calculate program income, but disagreed on the recommended correction. The
complete text of the auditee’s response, along with our evaluation of that response, can be
found in appendix B of this report.
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TABLE OF CONTENTS
Background and Objectives 4
Results of Audit
Finding 1: The Authority Could Not Properly Account for Block Grant Program 5
Income
Scope and Methodology 11
Internal Controls 12
Appendixes
A. Schedule of Funds to Be Put to Better Use 13
B. Auditee Comments and OIG’s Evaluation 14
3
BACKGROUND AND OBJECTIVES
The Salish and Kootenai Housing Authority (Authority) is the tribally designated housing entity for
the Confederated Salish and Kootenai Tribes. It is located on the Flathead Indian Reservation in
Western Montana. The Authority was organized to provide housing for qualified individuals. It is
governed by a board of up to seven commissioners who are appointed by the tribal council.
Consequently, the Authority is considered a component unit of the tribe.
The Authority is a reservation-wide agency responsible for planning, coordinating, and delivering
services, which support the purpose of the agency. It was organized and is operated to act as a
recipient of Native American Housing Assistance and Self Determination Act of 1996
(NAHASDA) Indian Housing Block Grant (Block Grant) funds, administer such funds in
accordance with NAHASDA; remedy unsafe and unsanitary housing conditions; provide
employment opportunities; improve the quality of life in all reservation communities; engage in
housing-related activities and services; and participate in other entities formed to accomplish any of
these purposes including acting as a general partner in limited partnerships.
The Authority developed, maintained, and operated low-rent and mutual help units assisted
under the United States Housing Act of 1937 (1937 Act), as amended. On October 1, 1997,
NAHASDA reorganized the system of housing assistance provided to Native Americans by the
U.S. Department of Housing and Urban Development (HUD), eliminating several separate
programs of assistance, and replaced them with a NAHASDA Block Grant program. For those
units previously assisted under the 1937 Act, the Block Grant program provided for continued
operating and maintenance assistance.
The Authority used Block Grant program funds to operate and maintain low-rent units and
rehabilitate mutual help units that were previously assisted under the 1937 Act. In fiscal year
2007, the Authority had 414 low-rent and 82 mutual help units. The regulations at 24 CFR
[Code of Federal Regulations] 1000.62(a) govern how rents collected from low-rent units and
proceeds of sale from mutual help units are allocated between the Block Grant program income
and the Authority as nonprogram income. The regulation states that Block Grant program
income does not include any amounts generated from the operation of 1937 Act units unless the
units are assisted with grant amounts and the income is attributable to such assistance. Public
and Indian Housing (PIH) Notice 2000-18 provides guidance on accounting for program income
generated by the use or disbursement of Block Grant funds.
Our objective was to determine whether the Authority calculated program income for Block
Grant-assisted 1937 Act properties in accordance with applicable HUD guidance, regulations,
and requirements and to observe uses of revenue from Block Grant-assisted 1937 Act properties.
4
RESULTS OF AUDIT
Finding 1: The Authority Could Not Properly Account for Block Grant
Program Income
The Authority did not allocate income from NAHASDA-assisted 1937 Act properties between its
general fund and NAHASDA Block Grant programs in accordance with HUD requirements.
Although the Authority’s records were sufficient to support a proper allocation, its accounting
systems failed to track NAHASDA’s cumulative investment in individual 1937 Act single-family
housing units. Additionally, the Authority overcalculated its nonprogram income by including an
allowable expense level (AEL) amount for 33 1937 Act units that were transferred to a non-
NAHASDA tax credit partnership. This condition occurred because (1) the Authority’s policies did
not follow Office of Management and Budget (OMB) Circular A-87 cost principles and classified
Block Grant expenditures for rehabilitation and capitol improvements as maintenance expenses, and
(2) the Authority’s accounting controls did not ensure that the correct number of NAHASDA-
assisted units was used in its program income calculation. As a result, the Authority understated
NAHASDA revenue by more than $184,000 from 1937 Act low-rent housing receipts.
HUD Requirements
The regulations at 24 CFR 1000.62(a) state that program income does not include any
amounts generated from the operation of 1937 Act units unless the units are assisted with
grant amounts and the income is attributable to such assistance. For low-rent units
receiving Block Grant program assistance, PIH Notice 2000-18 provides that the tribally
designated housing entity may retain as nonprogram income the lesser of total income or
46 percent of the AEL for the recipient times the number of units. For mutual help units
receiving Block Grant program assistance, the notice provides that the tribally designated
housing entity may retain the proceeds of the sale of units as nonprogram income.
However, HUD restricts the use of nonprogram income from mutual help unit sales to
housing activities, community facilities, or economic development activities that benefit
the community.
Section 3.4 of the notice also states that all income from a 1937 Act low-rent or mutual
help unit is NAHASDA program income once cumulative NAHASDA funding for
rehabilitation and capital expenditure meets or exceeds 40 percent of the maximum
allowable dwelling construction and equipment cost (DC&E), effective with the October
1, 1997, enactment of NAHASDA. According to the notice, the 40 percent threshold is
only a concept for accounting for program income and has no effect in determining what
is considered eligible formula current assisted stock under the Block Grant formula.
5
On July 9, 2002, HUD issued guidance to remind grant recipients of the program income
requirements pertaining to 1937 Act units supported with Block Grant funds. The guidance
noted that in the absence of an accounting system meeting the requirements of PIH Notice
2000-18 to allocate income attributable to the 1937 Act and Block Grant programs, all
income would be program income and would be required to be used for Block Grant
program purposes. PIH Notice 2000-18 also requires that the accounting system track the
total income by project and the total Block Grant-funded rehabilitation by unit.
NAHASDA-Funded
Rehabilitation Expenses Not
Properly Tracked
The Authority did not track NAHASDA’s cumulative investment in individual 1937 Act
single-family housing units as required by PIH Notice 2000-18, section 3.4. The
Authority’s accounting processes failed to reclassify 1937 Act units as NAHASDA units
when these units received NAHASDA-funded rehabilitation or capital improvements.
When this cumulative investment reaches the 40 percent of DC&E figure discussed
above, the unit is considered substantially rehabilitated by NAHASDA and becomes a
NAHASDA unit for program income purposes.
The Authority’s policy required the capitalization of repairs in excess of $5,000. In
addition, the Authority chose to incur rehabilitation costs using NAHASDA funds. If
rehabilitation was required, the Authority’s plan was to use other funds such as low-
income housing tax credits to fund the rehabilitation. In implementing its maintenance
policy, the Authority recorded no rehabilitation or modernization on its units and,
therefore, did not track the assistance provided for each unit. Modernization or
rehabilitation was only separated from other maintenance when “many rental units have
inadequate or out of date equipment or require common repair, rehabilitation, or
refurbishment and when operating funds are insufficient to meet anticipated costs.”
However, the Authority’s definition of rehabilitation includes many activities that
constitute capital expenditures and is not consistent with the definition of maintenance in
OMB Circular A-87 cost principles (2 CFR 225), appendix B, paragraph 25, which states:
Maintenance, operations, and repairs. Unless prohibited by law, the cost
of utilities, insurance, security, janitorial services, elevator service, upkeep
of grounds, necessary maintenance, normal repairs and alterations, and the
like are allowable to the extent that they: keep property (including Federal
property, unless otherwise provided for) in an efficient operating
condition, do not add to the permanent value of property or appreciably
prolong its intended life, and are not otherwise included in rental or other
charges for space. Costs which add to the permanent value of property or
appreciably prolong its intended life shall be treated as capital
expenditures.
6
Significant Block Grant-Funded
Capital Expenditures Observed
We reviewed the Authority’s NAHASDA-funded maintenance expenditures for 1937 Act
units and observed numerous examples of expenditures between 2002 and 2007 that
should have been classified as capital expenditures in conformance with OMB Circular
A-87 requirements. We also noted expenditures exceeding the Authority’s $5,000
capitalization threshold, which were not capitalized in the Authority’s accounting
records. We observed 26 units with capital expenditures exceeding $20,000 from 2002 to
2007.
Nine of the 26 units exceeded the 40 percent of DC&E threshold based on our review and
reclassification of capital expenditures as follows.
Units substantially rehabilitated with NAHASDA funds
Date of Unit Months since NAHASDA Beds 40 % of Exceeds
transition transition, as funds net DC&E DC&E by:
of Dec. 2006 of credits *
Aug. 31, 2004 1502 28 45,020 3 24,845 20,175
Dec. 31, 2005 2612 12 45,650 3 24,845 20,805
Jan. 3, 2006 1833 12 41,990 4 29,753 12,237
Mar. 22, 2006 2808 10 29,790 3 24,845 4,945
June 27, 2003 3104 43 26,715 2 22,690 4,025
Aug. 22, 2007 3028 0 23,290 2 22,690 600
May 31, 2007 3126 0 29,995 3 24,845 5,150
Apr. 10, 2007 349 0 31,538 2 22,690 8,848
May 18, 2007 702 0 32,894 3 24,845 8,049
Total months: 105
* Credits include reimbursements from residents and homeowner equity.
Mutual Help
Two mutual help units converted to low rent after substantial rehabilitation occurred and
will now produce NAHASDA revenue. Unit 1502, converted to unit 348 on August 31,
2004, and unit 2612 converted to unit 2824 on December 31, 2005. Neither unit
produced proceeds of sale.
Low Rent
Each month that a low-rent unit was not transitioned to NAHASDA, the Authority was
eligible to convert $97 to nonprogram income. The seven low-rent units, along with the
two converted mutual help units, will now produce $873 in NAHASDA revenue per
month or $10,476 per year, based on PIH Notice 2000-18, section 3.4, which limits
7
nonprogram income per unit to 46 percent of the AEL. The AEL figure is $211 per
month for the Authority, as listed in the appendix to PIH Notice 2000-18.
We also noted that four additional units were within $1,200 of exceeding the threshold.
Since the nine units above exceeded the 40 percent threshold, they should have been
transitioned as NAHASDA units, with all income from these units recognized as
NAHASDA revenue. The Authority’s failure to track the capital expenditures for the
nine units shown above allowed it to classify $10,172 (105 months times $97) in income
from these units as nonprogram income from the time that the 40 percent threshold was
met through December 2006. This amount should be reclassified as NAHASDA
revenue, and a similar adjustment will be required for future program income
computations.
Calculation of Nonprogram
Income
From October 2002 through December 2006, the Authority collected more than $2.1
million in gross income from its 381 NAHASDA-subsidized 1937 Act low-rent units.
However, the AEL calculation for allocating program and nonprogram income was based
on 414 low-rent units because the Authority did not remove 33 units that were transferred
into a low-income tax credit project in June 2002. These 33 units were not subsidized
with NAHASDA funds during this period.
Using the inflated AEL, the Authority recognized only $69,078 in program income over
the period for these units. Had the Authority used the proper unit count for the AEL, the
annual AEL amount would have decreased from $482,194 to $443,758, and the Authority
would have reported an additional $174,054 in NAHASDA program income earned by
the low-rent program.
Program income calculations
Program year end Sept. 30, Dec. 31, Dec. 31, Dec. 31, Totals
2003 2004 2005 2006
Total rent revenue $488,009 $636,214 $517,801 $487,081 $2,129,105
(from 381 units)
Less: 46% of total AEL
414 units (482,194) (602,743) (482,194) (482,194)
381 units (443,758) (554,698) (443,758) (443,758)
Net program income
414 units 5,815 33,471 35,607 4,887
381 units 44,251 81,516 74,043 43,323
Program income
414 units None $33,471 $35,607 None 69,078
381 units $44,251 $81,516 $74,043 $43,323 243,132
Underreported NAHASDA revenue $174,054
Note: If program income is less than $25,000, no program income is recognized.
8
Use of Nonprogram Income
We observed that the primary use of nonprogram income from NAHASDA-assisted 1937
Act units was to fund low-income housing tax credit properties. This nonprogram
income was commingled in a general fund with revenue from other Authority operations.
The Authority did not track how it spent the nonprogram income from its 1937 Act rental
units. However, during the period 2004 through 2006, it spent more on housing-related
activities than the amount of nonprogram income obtained from the NAHASDA-assisted
1937 Act rental units. Therefore, we determined that there was little risk of abuse of
nonprogram income.
Conclusion
Since the Authority did not have a compliant definition of maintenance in place and
disregarded capital expenditures, it did not track actual dwelling construction and
equipment costs for its 1937 Act units at the unit level. As a result, it did not ensure the
accuracy of its program income calculation for its 1937 Act units assisted with Block
Grant funds by recognizing NAHASDA revenue from assets substantially rehabilitated
using NAHASDA funds. In addition, the calculation contained an inflated AEL that
reduced the amount of program income attributed to NAHASDA.
Recommendations
We recommend that HUD require the Authority to
1A. Implement policies and procedures to determine program income in accordance
with HUD requirements, to include a corrected definition of maintenance and the
Authority’s ability to track Block Grant-funded rehabilitation and/or capital
expenses by 1937 Act unit from both contracts and internal work orders.
1B. Update its computation of program income, properly segregating the revenue and
AEL calculation for low-income housing tax credit properties from other 1937 Act
low-rent units and reclassifying $174,054, which was previously withdrawn from
the 1937 Act low-rent program as nonprogram income, as Block Grant funds.
1C. Reduce the number of 1937 Act units capable of producing nonprogram income by
the nine units that received substantial rehabilitation or capital expenses between
2002 and 2006 using Block Grant funds, which exceeded 40 percent of the
dwelling, construction, and equipment costs, and reclassify $10,172 as NAHASDA
revenue.
9
1D. Adjust the annual 2007 and forward program income calculations to include
revenue from all substantially rehabilitated units as NAHASDA revenue.
10
SCOPE AND METHODOLOGY
Our objective was to determine whether the tribe complied with criteria for program income
from Block Grant-assisted 1937 Act housing projects and to observe uses of revenue from Block
Grant-assisted 1937 Act properties. The criteria are contained in NAHASDA implementing
regulations found in 24 CFR 1000.62, HUD’s Office of Native American Programs’ guidance,
and external requirements such as those from the General Accounting Office and the Office of
Management and Budget. The audit steps were designed to gain an understanding of the 1937
Act income and related use restrictions, the accounting for associated program income, and
support used to calculate program and nonprogram income.
To accomplish our objectives, we reviewed the Authority’s calculation of program income from
Block Grant-assisted 1937 Act housing projects and related supporting data at its offices in
Pablo, Montana. We reviewed sufficient cost accounting system information to confirm whether
the accounting system was capable of tracking rehabilitation and/or capital expenditures at the
housing unit level, as required to remove nonprogram income. We also reviewed the system for
tracking the transition of unit income from a 1937 Act identity to a Block Grant identity.
Finally, we observed the use of nonprogram income generated from Block Grant-assisted 1937
Act units. Our observations included review of the Authority’s fiscal years 1999 through 2004
financial audits.
We reviewed the Authority’s accounting system for reports that might identify any units that
exceeded the 40 percent dwelling construction and equipment cost limit for the program income
calculation. Its new electronic system could only report back to its implementation in 2006 and
could not provide sufficient data to satisfy this tracking requirement. To further support these
conclusions, we reviewed records of maintenance and rehabilitation work performed at tenant
move-out and at the time of casualty damages.
We randomly selected a sample of 12 of the Authority’s 496 1937 Act units between Polson and
Dixon, Montana. These units included six low-rent units, three nonconveyed mutual help units,
and three low-rent units that had rehabilitation work funded with low-income housing tax credits.
We then performed site visits to the sample units to verify that rehabilitation work shown in the
Authority’s files had been performed. We also toured the projects to determine whether there
had been any significant rehabilitation work performed on other units.
The audit was conducted between August 6, 2007, and January 18, 2008. Our review covered
the period October 1, 2002, to December 31, 2006, which corresponds to the financial reporting
periods needing restatement of nonprogram income from the Block Grant program.
We performed our review in accordance with generally accepted government auditing standards.
11
INTERNAL CONTROLS
Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being achieved:
• Effectiveness and efficiency of operations,
• Reliability of financial reporting, and
• Compliance with applicable laws and regulations.
Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance.
Relevant Internal Controls
We determined the following internal controls were relevant to our audit objectives:
• The system for calculating and tracking the use of program income and
nonprogram income.
• The cost accounting system dedicated to identifying and collecting the cost of
individual tasks and assigning those costs to an end unit of production.
We assessed the relevant controls identified above.
A significant weakness exists if management controls do not provide reasonable
assurance that the process for planning, organizing, directing, and controlling program
operations will meet the organization’s objectives.
Significant Weaknesses
Based on our review, we believe the following item is a significant weakness:
• The Authority created policies and procedures for determining program income that
did not comply with applicable guidance and regulations. Its definitions of long-
term maintenance and rehabilitation were not consistent with OMB Circular A-87
and industry practices. The Authority did not track cumulative NAHASDA
rehabilitation or capital expenses for each property, as required, to properly allocate
the property’s share of income attributable to the Block Grant program.
12
APPENDIXES
Appendix A
SCHEDULE OF FUNDS TO BE PUT TO BETTER USE
Recommendation Funds to be put to better
number use 1/
1B $174,054
1C $10,172
Total $184,226
1/ Recommendations that funds be put to better use are estimates of amounts that could be
used more efficiently if an Office of Inspector General (OIG) recommendation is
implemented. This includes reductions in outlays, deobligation of funds, withdrawal of
interest subsidy costs not incurred by implementing recommended improvements,
avoidance of unnecessary expenditures noted in preaward reviews, and any other savings
which are specifically identified. Finding 1B questions $174,054 of the Authority’s
calculation of nonprogram income for the period July 1, 2002, through December 31,
2006. The questioned amount represents an error in the formula used by the Authority
caused by the removal of revenue from 33 units transferred to a low-income housing tax
credit program. Finding 1C questions $10,172 in NAHASDA revenue for nine low-rent
homes excluded from the Authority’s calculation of program income for the period
October 1, 2002, through December 31, 2006. The questioned amount represents units
removed from the 46 percent of AEL formula because the Authority failed to transition
these units to NAHASDA after they were substantially rehabilitated using Block Grant
funds.
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Appendix B
AUDITEE COMMENTS AND OIG’S EVALUATION
Ref to OIG Evaluation Auditee Comments
14
Comment 1
Comment 2
15
Comment 3
Comment 4
Comment 5
Comment 3
Comment 6
Comment 7
Names of the staff redacted for privacy.
16
Comment 3
Comment 8
Comment 9
Comment 10
17
Comment 10
Comment 11
18
OIG Evaluation of Auditee Comments
Comment 1 We discussed the Authority’s practices in the section labeled “Results of Audit.”
Comment 2 Negotiated rulemaking for the NAHASDA program took place within the
constraints of the federal laws and regulations controlling the government grants
management process. These standardized rules, applicable to grants from
essentially all federal agencies are outside the influence of negotiated rulemaking
without prior approval from the Office of Management and Budget (OMB).
Negotiated rulemaking resulted in the NAHASDA regulations at 24 CFR 1000.
The supplementary information to this regulation called for a committee to
address the need for accounting guidance for program income generated by the
combined use of NAHASDA grant amounts and other funds. The product of that
committee was PIH Notice 2000-18, which is guidance, not regulation.
Comment 3 The program income subcommittee did not define rehabilitation in any technical
terms other than that of capital expenditures, which are defined by OMB Circular
A-87 cost principles (2 CFR 225), appendix B, paragraph 25. Also, the
Authority’s definition of maintenance does not comply with OMB Circular A-87.
Since there is no definition of rehabilitation in the criteria, our position did not
attempt to question rehabilitation amounts lower than the Authority’s own
definition of capital expenditures, or $5,000. The definition of capital
expenditures and maintenance are defined by OMB Circular A-87, which is
specified by the NAHASDA regulation. The Authority’s understanding of this
circular is required to maintain the basic administrative capacity to manage a
federal grant program.
Authority records clearly demonstrate significant capital expenditures of
NAHASDA funds, much higher than this amount, which were not tracked by their
system. We observed numerous examples of NAHASDA funded capital
improvements to homes, such as replacing windows, siding, roofing, cabinetry,
and appliances. Many of these improvements will extend the useful lives and the
value of these homes, even at amounts under the Authority’s $5,000 capital
threshold. Yet, the Authority treated 26 rehabilitations exceeding $20,000 and
three rehabilitations exceeding $40,000 as maintenance.
Comment 4 Our results of audit questions the unit counts used in the Authority’s calculation
of program income, which is the basis for our questioned costs.
Comment 5 Note that the Authority’s citation includes the requirement for capital
expenditures to be considered in the calculation of substantial rehabilitation.
19
Comment 6 While there is no clear definition of rehabilitation in the NAHASDA regulations
or guidance, the guidance did relate it to other defined terms, such as capital
expenditures.
Comment 7 These 33 units were transferred to a Low Income Housing Tax Credit (LIHTC)
partnership to obtain significant rehabilitation and modernization. While we
acknowledge the Authority’s creative efforts to take advantage of other funding
opportunities, our review of maintenance contracts revealed that these
partnerships were not the only significant capital improvements occurring at the
Authority, as identified in our Results of Audit.
Comment 8 We believe it is irrefutable that a $40,000 investment in a property would impact
both the useful life and the value of the property and would constitute substantial
rehabilitation for any unit maintained by this Authority.
Comment 9 The date used in our calculation was the date the 33 units were transferred to the
control of the limited partnership. The Authority proposed using the date the
property began earning revenue which is inconsistent with their ownership status
and their established practice of segregating revenue by separate balance sheets
for the Authority and the tax credit partnerships. If the Authority wants to operate
these partnerships within NAHASDA, they would first need to be reviewed and
approved by HUD for compliance with established criteria.
Comment 10 The expenses for homes included in this calculation were paid using NAHASDA
IHBG grant funds and the nonprogram income was transferred to fund the LIHTC
partnership. It is not clear what revenues or expenses are left to offset.
Comment 11 We hope that the Authority continues to pursue creative solutions to affordable
housing, both inside and outside of the NAHASDA program. However, as
changes in tribal leadership and policy may occur, the purpose of these program
income rules is to ensure NAHASDA grant funds continue to reach the intended
beneficiaries.
20
Salish and Kootenai Housing Authority, Pablo, Montana, Did Not Properly Recognize and Account for Program Income from 1937 Act Housing Projects
Published by the Department of Housing and Urban Development, Office of Inspector General on 2008-04-28.
Below is a raw (and likely hideous) rendition of the original report. (PDF)