Audit 304973

2024-001 FEDERAL COMPLIANCE – WAITING LIST PREFERENCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.54(d), the PHA’s administrative plan must include procedures for the “Selection and admission of applicants from the PHA waiting list, including any PHA admission preferences, procedures for removing applicant names from the waiting list, and procedures for closing and reopening the PHA waiting list.” Condition: While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.

2024-002 FEDERAL COMPLIANCE – TENANT DOCUMENTATION Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility and Special Provisions Criteria: HUD requires Public Housing Authorities (PHA) to properly document the eligibility of tenants, properly calculate benefits based on tenant income and determine rent is reasonable. Condition: During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • Three instances in which the income utilized to calculate benefits did not agree to documentation in the tenant file. • One instance in which a tenant was accepted due to homeless status, but documentation of homelessness was not included in the tenant file. • Rent Reasonableness Form with no conclusion as to whether rent was reasonable. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.

2024-003 FEDERAL COMPLIANCE – RENT INCREASE NOTICE Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: The City’s Administrative Plan requires that tenants be given a 30-day notice before the effective date of a rent increase that is based on the results of an annual recertification. Condition: We noted one instance after year-end in which a tenant was only given a 4-day notice before the effective date of a rent increase. Effect and Questioned Costs: Noncompliance with the Administrative Plan for the program. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure tenants are given a 30-day notice prior to any rent increases that are result from an annual recertification. Management’s Response: Each caseworker has been issued an admin plan and refer to it often. Staff has been made aware that an increase in rent must be issued a 30 day notice. If the tenant rent decreases, the decrease is to take effect immediately. Administrator is also auditing files to help alleviate any errors.

2024-004 FEDERAL COMPLIANCE – UTILITY ALLOWANCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.517, the PHA must maintain an up-to-date utility schedule by annually reviewing utility rate data and adjusting its utility allowance schedule if there has been a rate change of 10 percent or more. Condition: We noted that the utility rate data was analyzed and there was a more than 10 precent change for several categories. However, the utility allowance schedule was not updated during the year. Effect and Questioned Costs: Noncompliance with 24 CFR 982.517 Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that the utility allowance schedule is reviewed and updated annually as necessary with the change being approved by the Board of Commissioners. Management’s Response: Based on the review of utility rate data during FY24, the utility allowance schedule was updated and approved by the Board of Commissioners in February 2024.

2024-001 FEDERAL COMPLIANCE – WAITING LIST PREFERENCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.54(d), the PHA’s administrative plan must include procedures for the “Selection and admission of applicants from the PHA waiting list, including any PHA admission preferences, procedures for removing applicant names from the waiting list, and procedures for closing and reopening the PHA waiting list.” Condition: While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.

2024-002 FEDERAL COMPLIANCE – TENANT DOCUMENTATION Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility and Special Provisions Criteria: HUD requires Public Housing Authorities (PHA) to properly document the eligibility of tenants, properly calculate benefits based on tenant income and determine rent is reasonable. Condition: During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • Three instances in which the income utilized to calculate benefits did not agree to documentation in the tenant file. • One instance in which a tenant was accepted due to homeless status, but documentation of homelessness was not included in the tenant file. • Rent Reasonableness Form with no conclusion as to whether rent was reasonable. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.

2024-003 FEDERAL COMPLIANCE – RENT INCREASE NOTICE Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: The City’s Administrative Plan requires that tenants be given a 30-day notice before the effective date of a rent increase that is based on the results of an annual recertification. Condition: We noted one instance after year-end in which a tenant was only given a 4-day notice before the effective date of a rent increase. Effect and Questioned Costs: Noncompliance with the Administrative Plan for the program. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure tenants are given a 30-day notice prior to any rent increases that are result from an annual recertification. Management’s Response: Each caseworker has been issued an admin plan and refer to it often. Staff has been made aware that an increase in rent must be issued a 30 day notice. If the tenant rent decreases, the decrease is to take effect immediately. Administrator is also auditing files to help alleviate any errors.

2024-004 FEDERAL COMPLIANCE – UTILITY ALLOWANCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.517, the PHA must maintain an up-to-date utility schedule by annually reviewing utility rate data and adjusting its utility allowance schedule if there has been a rate change of 10 percent or more. Condition: We noted that the utility rate data was analyzed and there was a more than 10 precent change for several categories. However, the utility allowance schedule was not updated during the year. Effect and Questioned Costs: Noncompliance with 24 CFR 982.517 Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that the utility allowance schedule is reviewed and updated annually as necessary with the change being approved by the Board of Commissioners. Management’s Response: Based on the review of utility rate data during FY24, the utility allowance schedule was updated and approved by the Board of Commissioners in February 2024.