Finding No. 2023 - 001:
Federal Agency: Department of Housing and Urban Development ("HUD")
Federal Program Title: Moving to Work Demonstration Program (HCVP Only)
Federal Assistance Listing Number: 14.881
Award Period: January 1, 2023 through December 31, 2023
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Condition/Context
A sample of 60 tenant files tested found that 10 files did not have HUD-50058 data uploaded to the
PIH Information Center ("PIC") in a timely manner. Our sample was a statistically valid sample.
Questioned Costs
N/A
Criteria
Per the agreement between BRHP and the Housing Authority of Baltimore City, BRHP shall create
an Administrative Plan for the program. Per BRHP's Program Administrative Plan, tenant
information must be uploaded to the PIC system for each HUD-50058 report completed no later
than 60 calendar days from the effective date of any action recorded on the form HUD-50058.
Cause
Of the 10 files selected, 8 were families submitted to PIC in 2022 prior to a revision in BRHP's
process to submit weekly. Two of the families were submitted in 2023 with action 7's for an interim
move, a 50058 action. One of these two had an action 7 effective on April 21, 2023, that was
approved on June 23, 2023, and submitted to PIC on June 27, 2023. The other had an action 7
effective May 1, 2023, that was approved on August 15, 2023, and submitted to PIC on August 18,
2023. Both files were submitted within the week of the files being approved during BRHP's weekly
PIC submission but were late due to the late 50058 approval.
Effect
The delay in uploading information to the PIC system may result in inaccurate reporting to HUD
which is used for funding purposes.
Identification of a Repeat Finding
This is a repeat finding from the immediate previous audit, Finding No. 2022-002.
Recommendations
We recommend that BRHP follow its internal policy of reporting to HUD on a weekly basis.
Views of the Responsible Officials
At this time, all files selected for the audit have corresponding records successfully submitted to
HUD through the PIC submission portal. BRHP will continue weekly PIC submissions and clearing
of fatal errors. The late PIC submissions identified were a result of late 50058 approvals which
resulted in late PIC submission. The 50058's were uploaded to PIC within 5 days of the approval.
BRHP monitors 50058's related to moves in a weekly leasing report. In addition, BRHP meets biweekly
to discuss the report. BRHP will monitor the weekly leasing report to review the lease
effective dates to HAP executed dates to ensure the actions are approved timely.
Finding No. 2023 - 002:
Federal Agency: Department of Housing and Urban Development
Federal Program Title: Moving to Work Demonstration Program (HCVP Only)
Federal Assistance Listing Number: 14.881
Award Period: January 1, 2023 through December 31, 2023
Compliance Requirement: Special Tests and Provisions
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Condition/Context
A sample of 60 tenant files tested for special tests found the following exceptions:
Three (3) of 60 files tested did not have a housing quality standards inspection performed
within 25 months of the previous inspection. Our sample was a statistically valid sample.
Questioned Costs
N/A
Criteria
The Program Administrative Plan states that BRHP will attempt to inspect all units under contract in
accordance with its Housing Quality Standards ("HQS") and the units must pass inspection at least
once every 25 months.
Cause
Two of the three BRHP families had inspections completed within the required timeframe of 25
months by BRHP's third-party contractor, however, both failed HQS. The reinspections of both units
were not scheduled in a timely manner by the contractor.
Effect
BRHP is not in compliance with its administrative plan and the Uniform Guidance compliance
requirements.
Identification of a Repeat Finding
This is a repeat finding from the immediate previous audit, Finding No. 2022-003.
Recommendations
We recommend that BRHP review their process for tracking and scheduling inspections to ensure
compliance.
Views of the Responsible Officials
The two files noted for missed inspections have since been scheduled for reinspection, and one
passed HQS inspection on March 14, 2024. The other was scheduled for inspection on March 12,
2024, and resulted in a Broken Scheduled Appointment ("BSA"). A second inspection was
scheduled for March 28, 2024. BRHP has added two elements to the reporting process for
inspections. The weekly leasing report now identifies failed inspections within the period. The
second element is the Inspection Audit report. BRHP has increased the reporting metric from
monthly to bi-weekly and included a pivot table to ensure the report is user friendly to staff that are
responsible for reviewing. Both changes allow for greater visibility and frequency to ensure missed
inspections are identified.
Finding No. 2023 - 001:
Federal Agency: Department of Housing and Urban Development ("HUD")
Federal Program Title: Moving to Work Demonstration Program (HCVP Only)
Federal Assistance Listing Number: 14.881
Award Period: January 1, 2023 through December 31, 2023
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Condition/Context
A sample of 60 tenant files tested found that 10 files did not have HUD-50058 data uploaded to the
PIH Information Center ("PIC") in a timely manner. Our sample was a statistically valid sample.
Questioned Costs
N/A
Criteria
Per the agreement between BRHP and the Housing Authority of Baltimore City, BRHP shall create
an Administrative Plan for the program. Per BRHP's Program Administrative Plan, tenant
information must be uploaded to the PIC system for each HUD-50058 report completed no later
than 60 calendar days from the effective date of any action recorded on the form HUD-50058.
Cause
Of the 10 files selected, 8 were families submitted to PIC in 2022 prior to a revision in BRHP's
process to submit weekly. Two of the families were submitted in 2023 with action 7's for an interim
move, a 50058 action. One of these two had an action 7 effective on April 21, 2023, that was
approved on June 23, 2023, and submitted to PIC on June 27, 2023. The other had an action 7
effective May 1, 2023, that was approved on August 15, 2023, and submitted to PIC on August 18,
2023. Both files were submitted within the week of the files being approved during BRHP's weekly
PIC submission but were late due to the late 50058 approval.
Effect
The delay in uploading information to the PIC system may result in inaccurate reporting to HUD
which is used for funding purposes.
Identification of a Repeat Finding
This is a repeat finding from the immediate previous audit, Finding No. 2022-002.
Recommendations
We recommend that BRHP follow its internal policy of reporting to HUD on a weekly basis.
Views of the Responsible Officials
At this time, all files selected for the audit have corresponding records successfully submitted to
HUD through the PIC submission portal. BRHP will continue weekly PIC submissions and clearing
of fatal errors. The late PIC submissions identified were a result of late 50058 approvals which
resulted in late PIC submission. The 50058's were uploaded to PIC within 5 days of the approval.
BRHP monitors 50058's related to moves in a weekly leasing report. In addition, BRHP meets biweekly
to discuss the report. BRHP will monitor the weekly leasing report to review the lease
effective dates to HAP executed dates to ensure the actions are approved timely.
Finding No. 2023 - 002:
Federal Agency: Department of Housing and Urban Development
Federal Program Title: Moving to Work Demonstration Program (HCVP Only)
Federal Assistance Listing Number: 14.881
Award Period: January 1, 2023 through December 31, 2023
Compliance Requirement: Special Tests and Provisions
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Condition/Context
A sample of 60 tenant files tested for special tests found the following exceptions:
Three (3) of 60 files tested did not have a housing quality standards inspection performed
within 25 months of the previous inspection. Our sample was a statistically valid sample.
Questioned Costs
N/A
Criteria
The Program Administrative Plan states that BRHP will attempt to inspect all units under contract in
accordance with its Housing Quality Standards ("HQS") and the units must pass inspection at least
once every 25 months.
Cause
Two of the three BRHP families had inspections completed within the required timeframe of 25
months by BRHP's third-party contractor, however, both failed HQS. The reinspections of both units
were not scheduled in a timely manner by the contractor.
Effect
BRHP is not in compliance with its administrative plan and the Uniform Guidance compliance
requirements.
Identification of a Repeat Finding
This is a repeat finding from the immediate previous audit, Finding No. 2022-003.
Recommendations
We recommend that BRHP review their process for tracking and scheduling inspections to ensure
compliance.
Views of the Responsible Officials
The two files noted for missed inspections have since been scheduled for reinspection, and one
passed HQS inspection on March 14, 2024. The other was scheduled for inspection on March 12,
2024, and resulted in a Broken Scheduled Appointment ("BSA"). A second inspection was
scheduled for March 28, 2024. BRHP has added two elements to the reporting process for
inspections. The weekly leasing report now identifies failed inspections within the period. The
second element is the Inspection Audit report. BRHP has increased the reporting metric from
monthly to bi-weekly and included a pivot table to ensure the report is user friendly to staff that are
responsible for reviewing. Both changes allow for greater visibility and frequency to ensure missed
inspections are identified.