Audit 309996

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files - Noncompliance & Significant Deficiency Housing Choice Voucher Program – ALN 14.871 Condition & Cause: We reviewed forty-two (42) Housing Choice Voucher tenant files and noted eleven (11) files that were out of compliance, or 26.2% of our sample. The discrepancies noted in the files are as follows: • Three (3) instances of an annual reexamination that was completed late; • Three (3) instances of HAP register disagreement due to delayed End of Participation (EOP) processing; • Three (3) instances of improper income verification; • Four (4) instances of omitted zero income procedures outlined in the Agency’s Admin Plan; • One (1) instance of missing annual inspection documentation; • One (1) instance of missing HUD form 9886; and • Two (2) instances of missing EIV We reviewed the HAP ledgers for the three (3) files which did not agree with the HAP register due to a delay in processing the participant’s EOP. In each case, we found that the landlord did not receive HAP improperly. We noted that during the period in review, the Agency experienced an abundance of staff turnover. This included Executive staff and the departments that oversee voucher administration. We believe this contributed to the compliance discrepancies. Criteria: The Code of Federal regulations, the Housing Authority Administrative Plan and specific HUD guidelines in documenting and maintaining Housing Choice Voucher tenant files. Effect: Failure to conduct timely recertifications and to properly calculate annual income can result in a misstatement of HAP expense leading to improper funding for the HCV program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding. Recommendation: We recommend that the Agency conduct a tenant file audit of existing tenants in the HCV program to determine the extent of any additional misstatements of HAP expense. We also recommend that the Agency increase their monitoring and quality control review of the HCV program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Our experience with agencies that increase monitoring and review of the files is that there are dramatically decreased error rates. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Finding 2023-002 – Continuum of Care Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness Continuum of Care Program - subsidy ALN 14.267 Condition & Cause: We selected a sample of five (5) files for review. We noted the following errors of noncompliance: • Two (2) files which disagreed with the applicable HAP register due to delays in annual or interim updates; • Two (2) files which contained no paperwork pertaining to the period examined; and • One (1) file which contained a miscalculation of annual income and no signed authorization for the release of information. We noted that subsequent to year end new staff was placed in charge of the program. Per discussion, the focus has been bringing current participants into compliance. We elected to randomly sample an additional five (5) files from a list of current participants subsequent to year end. We reviewed these files for existence, presence of the action in agreement with the March 2024 HAP register, and timeliness of completion of annual reexaminations. This subsequent review revealed: • Two (2) files for which the recertification was completed more than three months past the due date; • One (1) file in which there was no documentation of the annual update; and • One (1) file which staff was unable to locate. Criteria: The Code of Federal Regulations 24 part 578, the Housing Authority’s Admin Plan, and specific HUD guidelines in documenting and maintaining the Continuum of Care tenant files. Effect: Failure to conduct timely recertifications and to properly calculate HAP can result in a misstatement of HAP expense leading to improper funding for the CoC program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding. Recommendation: We recommend that the Agency conduct a thorough tenant file audit of existing tenants in the Continuum of Care program. We also recommend that the Agency increase their monitoring and review of the Continuum of Care program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Questioned Costs: None Repeat Finding: Yes Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files - Noncompliance & Significant Deficiency Housing Choice Voucher Program – ALN 14.871 Condition & Cause: We reviewed forty-two (42) Housing Choice Voucher tenant files and noted eleven (11) files that were out of compliance, or 26.2% of our sample. The discrepancies noted in the files are as follows: • Three (3) instances of an annual reexamination that was completed late; • Three (3) instances of HAP register disagreement due to delayed End of Participation (EOP) processing; • Three (3) instances of improper income verification; • Four (4) instances of omitted zero income procedures outlined in the Agency’s Admin Plan; • One (1) instance of missing annual inspection documentation; • One (1) instance of missing HUD form 9886; and • Two (2) instances of missing EIV We reviewed the HAP ledgers for the three (3) files which did not agree with the HAP register due to a delay in processing the participant’s EOP. In each case, we found that the landlord did not receive HAP improperly. We noted that during the period in review, the Agency experienced an abundance of staff turnover. This included Executive staff and the departments that oversee voucher administration. We believe this contributed to the compliance discrepancies. Criteria: The Code of Federal regulations, the Housing Authority Administrative Plan and specific HUD guidelines in documenting and maintaining Housing Choice Voucher tenant files. Effect: Failure to conduct timely recertifications and to properly calculate annual income can result in a misstatement of HAP expense leading to improper funding for the HCV program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding. Recommendation: We recommend that the Agency conduct a tenant file audit of existing tenants in the HCV program to determine the extent of any additional misstatements of HAP expense. We also recommend that the Agency increase their monitoring and quality control review of the HCV program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Our experience with agencies that increase monitoring and review of the files is that there are dramatically decreased error rates. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Finding 2023-002 – Continuum of Care Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness Continuum of Care Program - subsidy ALN 14.267 Condition & Cause: We selected a sample of five (5) files for review. We noted the following errors of noncompliance: • Two (2) files which disagreed with the applicable HAP register due to delays in annual or interim updates; • Two (2) files which contained no paperwork pertaining to the period examined; and • One (1) file which contained a miscalculation of annual income and no signed authorization for the release of information. We noted that subsequent to year end new staff was placed in charge of the program. Per discussion, the focus has been bringing current participants into compliance. We elected to randomly sample an additional five (5) files from a list of current participants subsequent to year end. We reviewed these files for existence, presence of the action in agreement with the March 2024 HAP register, and timeliness of completion of annual reexaminations. This subsequent review revealed: • Two (2) files for which the recertification was completed more than three months past the due date; • One (1) file in which there was no documentation of the annual update; and • One (1) file which staff was unable to locate. Criteria: The Code of Federal Regulations 24 part 578, the Housing Authority’s Admin Plan, and specific HUD guidelines in documenting and maintaining the Continuum of Care tenant files. Effect: Failure to conduct timely recertifications and to properly calculate HAP can result in a misstatement of HAP expense leading to improper funding for the CoC program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding. Recommendation: We recommend that the Agency conduct a thorough tenant file audit of existing tenants in the Continuum of Care program. We also recommend that the Agency increase their monitoring and review of the Continuum of Care program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Questioned Costs: None Repeat Finding: Yes Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.