In a new audit report, HUD’s Office of Inspector General (OIG) questioned certain costs paid by a public housing authority (PHA) for travel by the PHA’s commissioners. The OIG alleges violations of uniform cost principals at 2 CFR Part 200, state open meeting laws, as well as the PHA’s own policies. The report is a reminder to:
- Remember that not all costs incurred while on official PHA business/educational travel are eligible for reimbursement with federal funds. For example, PHAs should not reimburse commissioners or staff for alcoholic beverages purchased while on official business, even if other aspects of a meal are reimbursable. Although not addressed in this audit, many entertainment and social activity costs are also unallowable, though there are exceptions, such as situations in which such costs have a programmatic purpose.
- Be mindful of a PHA’s internal policies pertaining to travel and reimbursements. The OIG and others will often look to internal policies to address situations that may be otherwise allowable under federal requirements.
- Pay attention to potential conflict-of-interest situations. A PHA’s ACCs with HUD as well as procurement regulations and some state laws prohibit certain types of financial arrangements involving a PHA and its staff or commissioners. The ACCs in particular will prohibit these arrangements during and for one year after a commissioner’s tenure.