Finding 2021-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2020-005 Federal Program: Section 8 Housing Choice Vouchers. Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.516, the Housing Authority must conduct a reexamination of family income and composition at least annually. Third-party verification of family income, value of assets, expenses deducted from income, and other factors that affect adjusted income must be obtained and documented. The Housing Authority must determine income eligibility and calculate the tenant's rent payment using the documentation from third-party verification in accordance with 24 CFR part 5 subpart F. The Housing Authority is also required to submit HUD-50058, Family Report, for each examination per 24 CFR part 908. The amount paid for housing assistance payments (HAP) must correspond to HUD-50058. Condition/Context: No documentation of family income, composition, third-party verification, or HUD‑50058 were provided for one of the twenty five tenants selected for testing for the required reexamination during the fiscal year. Our sample was not statistically valid. Questioned Costs: Housing assistance payments for the tenant noted above is not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the eligibility determinations done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old. Effect: The Housing Authority may be making inaccurate or ineligible HAP payments on behalf of tenants. Recommendation: The Housing Authority should ensure their vendors properly maintain documentation regarding eligibility determinations. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program vouchers.
Finding 2021-003: Special Tests and Provisions - Reasonable Rent Repeat Finding of Portions of 2020-004 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.54(d)(15), the Housing Authority must adopt a written administrative plan that establishes local policies for the method of determining that rent paid to an owner is a reasonable rent, initially and during the term of the housing assistance payment contract. Per 24 CFR section 982.507, the Housing Authority must determine that the rent to an owner is reasonable before any subsequent increase in rent is paid to the owner. Condition/Context: We were able to determine that the Housing Authority has a written administrative plan addessing reasonable rent determinations. The Housing Authority was however unable to provide documentation of reasonable rent for the period under audit for the eleven tenants selected for testing. Our sample was not statistically valid. Questioned Costs: Not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the rent reasonableness procedures performed in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old and maybe have been purged. Effect: Rent paid to landlords may not be reasonable in comparison to other comparable unassisted units. Recommendation: The Housing Authority should ensure the vendor administering the program maintains proper records of rent reasonableness. The Housing Authority should also ensure it has a written policy for the method of determining that rent paid to an owner is a reasonable rent as required by 24 CFR section 982.54(d)(15). Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation as required by 24 CFR section 982.54(d)(15). We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program.
Finding 2021-004: Special Tests and Provisions - Housing Quality Standards (HQS) Inspections and HQS Enforcement Repeat Finding of Portions of 2020-002 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.405, the Housing Authority must inspect units prior to the initial term of the lease, at least biennially during assisted occupancy, and at other times as needed, to determine if units meet Housing Quality Standards (HQS). The Housing Authority must also conduct supervisory quality control HQS inspections. Per 24 CFR section 982.404, the Housing Authority must take prompt and vigorous action to enforce the owner obligations for HQS. Housing assistance payments must not be made to units that fail to meet HQS, unless the owner corrects the defect within the required period. Condition/Context: During our testing over the related compliance requirements, we observed the following: We were unable to determine whether the Housing Authority performed quality control re inspections, as required by 24 CFR section 982.405(b). Our sample was not statistically valid. Questioned Costs: Not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the HQS inspections done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old and may have been purged. Effect: Units that fail to meet HQS could endanger the health and safety of tenants. Recommendation: The Housing Authority should ensure the vendor administering the program maintains proper inspection logs and documentation of quality control re-inspections. The Housing Authority should also review its processes to ensure units are inspected based on the requirements in 24 CFR section 982.404. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation to prove compliance with HQS inspection requirements. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program.
Finding 2021-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2020-005 Federal Program: Section 8 Housing Choice Vouchers. Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.516, the Housing Authority must conduct a reexamination of family income and composition at least annually. Third-party verification of family income, value of assets, expenses deducted from income, and other factors that affect adjusted income must be obtained and documented. The Housing Authority must determine income eligibility and calculate the tenant's rent payment using the documentation from third-party verification in accordance with 24 CFR part 5 subpart F. The Housing Authority is also required to submit HUD-50058, Family Report, for each examination per 24 CFR part 908. The amount paid for housing assistance payments (HAP) must correspond to HUD-50058. Condition/Context: No documentation of family income, composition, third-party verification, or HUD‑50058 were provided for one of the twenty five tenants selected for testing for the required reexamination during the fiscal year. Our sample was not statistically valid. Questioned Costs: Housing assistance payments for the tenant noted above is not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the eligibility determinations done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old. Effect: The Housing Authority may be making inaccurate or ineligible HAP payments on behalf of tenants. Recommendation: The Housing Authority should ensure their vendors properly maintain documentation regarding eligibility determinations. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program vouchers.
Finding 2021-003: Special Tests and Provisions - Reasonable Rent Repeat Finding of Portions of 2020-004 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.54(d)(15), the Housing Authority must adopt a written administrative plan that establishes local policies for the method of determining that rent paid to an owner is a reasonable rent, initially and during the term of the housing assistance payment contract. Per 24 CFR section 982.507, the Housing Authority must determine that the rent to an owner is reasonable before any subsequent increase in rent is paid to the owner. Condition/Context: We were able to determine that the Housing Authority has a written administrative plan addessing reasonable rent determinations. The Housing Authority was however unable to provide documentation of reasonable rent for the period under audit for the eleven tenants selected for testing. Our sample was not statistically valid. Questioned Costs: Not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the rent reasonableness procedures performed in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old and maybe have been purged. Effect: Rent paid to landlords may not be reasonable in comparison to other comparable unassisted units. Recommendation: The Housing Authority should ensure the vendor administering the program maintains proper records of rent reasonableness. The Housing Authority should also ensure it has a written policy for the method of determining that rent paid to an owner is a reasonable rent as required by 24 CFR section 982.54(d)(15). Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation as required by 24 CFR section 982.54(d)(15). We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program.
Finding 2021-004: Special Tests and Provisions - Housing Quality Standards (HQS) Inspections and HQS Enforcement Repeat Finding of Portions of 2020-002 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.405, the Housing Authority must inspect units prior to the initial term of the lease, at least biennially during assisted occupancy, and at other times as needed, to determine if units meet Housing Quality Standards (HQS). The Housing Authority must also conduct supervisory quality control HQS inspections. Per 24 CFR section 982.404, the Housing Authority must take prompt and vigorous action to enforce the owner obligations for HQS. Housing assistance payments must not be made to units that fail to meet HQS, unless the owner corrects the defect within the required period. Condition/Context: During our testing over the related compliance requirements, we observed the following: We were unable to determine whether the Housing Authority performed quality control re inspections, as required by 24 CFR section 982.405(b). Our sample was not statistically valid. Questioned Costs: Not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the HQS inspections done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old and may have been purged. Effect: Units that fail to meet HQS could endanger the health and safety of tenants. Recommendation: The Housing Authority should ensure the vendor administering the program maintains proper inspection logs and documentation of quality control re-inspections. The Housing Authority should also review its processes to ensure units are inspected based on the requirements in 24 CFR section 982.404. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation to prove compliance with HQS inspection requirements. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program.