Finding Reference: 2023-002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Voucher Cluster
Assistance Listing Number: 14.871 and 14.879
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections)
Classification of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance
Criteria
Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority was required to resume biennial inspections by December 31, 2021. The Authority was required to conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and was required to conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022.
Condition
From a total population of about 15,410 tenants for the fiscal year ended September 30, 2023, we selected a statistically valid sample of one monthly subsidy payment for each of 60 selected tenants, and identified fifteen tenants whose HQS inspections were completed past the due dates and seven tenants whose HQS inspection reports were not provided for review.
Cause of Condition
The Authority’s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed.
Effect
The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality.
Questioned Costs
Known questioned costs of $179,377 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 60 participants that totaled $1,550,585 in HAPs to the total HAPs of $385,748,113 for the year, results in likely questioned costs of $44,624,677.
Identification of Repeat Finding
This is a repeat of finding 2022-003 reported for the year ended September 30, 2022.
Recommendation
The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Voucher Cluster
Assistance Listing Number: 14.871 and 14.879
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections)
Classification of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance
Criteria
Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority was required to resume biennial inspections by December 31, 2021. The Authority was required to conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and was required to conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022.
Condition
From a total population of about 15,410 tenants for the fiscal year ended September 30, 2023, we selected a statistically valid sample of one monthly subsidy payment for each of 60 selected tenants, and identified fifteen tenants whose HQS inspections were completed past the due dates and seven tenants whose HQS inspection reports were not provided for review.
Cause of Condition
The Authority’s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed.
Effect
The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality.
Questioned Costs
Known questioned costs of $179,377 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 60 participants that totaled $1,550,585 in HAPs to the total HAPs of $385,748,113 for the year, results in likely questioned costs of $44,624,677.
Identification of Repeat Finding
This is a repeat of finding 2022-003 reported for the year ended September 30, 2022.
Recommendation
The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Voucher Cluster
Assistance Listing Number: 14.871 and 14.879
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections)
Classification of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance
Criteria
Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority was required to resume biennial inspections by December 31, 2021. The Authority was required to conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and was required to conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022.
Condition
From a total population of about 15,410 tenants for the fiscal year ended September 30, 2023, we selected a statistically valid sample of one monthly subsidy payment for each of 60 selected tenants, and identified fifteen tenants whose HQS inspections were completed past the due dates and seven tenants whose HQS inspection reports were not provided for review.
Cause of Condition
The Authority’s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed.
Effect
The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality.
Questioned Costs
Known questioned costs of $179,377 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 60 participants that totaled $1,550,585 in HAPs to the total HAPs of $385,748,113 for the year, results in likely questioned costs of $44,624,677.
Identification of Repeat Finding
This is a repeat of finding 2022-003 reported for the year ended September 30, 2022.
Recommendation
The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-003
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Section 8 Housing Choice Vouchers
Federal Catalog Number: 14.871
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions - HQS Enforcement
Classification of Finding: Significant Deficiency in Internal Control over Compliance
Instance of Noncompliance
Criteria
Pursuant to 24 CFR 982.404(a)(3), the Authority must not make any housing assistance payments (HAP) for a dwelling unit that fails to meet the housing quality standard (HQS), unless the owner corrects the defect within the period specified by the Authority and the Authority verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). Furthermore, 24 CFR 982.404(b)(2) states that if an HQS breach caused by the family is life threatening, the family must correct the defect within no more than 24 hours. For other family-caused defects, the family must correct the defect within no more than 30 calendar days (or any PHA-approved extension).
Condition
Of the total of 3,515 tenants with failed inspections during the fiscal year, we identified three cases in a statistically valid sample of 60 failed inspections in which the Authority did not perform follow-up inspections within the required timeframe to verify identified defects were corrected and/or did not abate HAPs for defects that were not corrected within the required timeframe.
Cause of Condition
The Authority does not have adequate controls in place to ensure that the HQS are being enforced or completed in a timely manner and that HAPs are being properly withheld.
Effect
The Authority is not in compliance with the HQS enforcement requirements, which may result in tenants living in unsafe housing units. In addition, the Authority may be paying HAPs to property owners whose units have inadequate housing quality and may be incorrectly withholding HAPs to landlords who have properly corrected the deficiencies within the required timeframe.
Questioned Costs
Known questioned costs totaled $10,770, which represents HAPs made for months in which the required follow-up inspections were not performed or HAPs were not abated after failed re-inspections.
Identification of Repeat Finding
This is not a repeat finding in the immediate prior audit period.
Recommendation
The Authority should continue to develop procedures and strengthen its internal controls related to HQS enforcement. The Authority should also regularly review the list of failed inspections to verify that units with failed HQS inspections have the housing assistance payments properly withheld and that property owners whose units passed re-inspection are properly paid.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-003
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Section 8 Housing Choice Vouchers
Federal Catalog Number: 14.871
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions - HQS Enforcement
Classification of Finding: Significant Deficiency in Internal Control over Compliance
Instance of Noncompliance
Criteria
Pursuant to 24 CFR 982.404(a)(3), the Authority must not make any housing assistance payments (HAP) for a dwelling unit that fails to meet the housing quality standard (HQS), unless the owner corrects the defect within the period specified by the Authority and the Authority verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). Furthermore, 24 CFR 982.404(b)(2) states that if an HQS breach caused by the family is life threatening, the family must correct the defect within no more than 24 hours. For other family-caused defects, the family must correct the defect within no more than 30 calendar days (or any PHA-approved extension).
Condition
Of the total of 3,515 tenants with failed inspections during the fiscal year, we identified three cases in a statistically valid sample of 60 failed inspections in which the Authority did not perform follow-up inspections within the required timeframe to verify identified defects were corrected and/or did not abate HAPs for defects that were not corrected within the required timeframe.
Cause of Condition
The Authority does not have adequate controls in place to ensure that the HQS are being enforced or completed in a timely manner and that HAPs are being properly withheld.
Effect
The Authority is not in compliance with the HQS enforcement requirements, which may result in tenants living in unsafe housing units. In addition, the Authority may be paying HAPs to property owners whose units have inadequate housing quality and may be incorrectly withholding HAPs to landlords who have properly corrected the deficiencies within the required timeframe.
Questioned Costs
Known questioned costs totaled $10,770, which represents HAPs made for months in which the required follow-up inspections were not performed or HAPs were not abated after failed re-inspections.
Identification of Repeat Finding
This is not a repeat finding in the immediate prior audit period.
Recommendation
The Authority should continue to develop procedures and strengthen its internal controls related to HQS enforcement. The Authority should also regularly review the list of failed inspections to verify that units with failed HQS inspections have the housing assistance payments properly withheld and that property owners whose units passed re-inspection are properly paid.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Voucher Cluster
Assistance Listing Number: 14.871 and 14.879
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections)
Classification of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance
Criteria
Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority was required to resume biennial inspections by December 31, 2021. The Authority was required to conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and was required to conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022.
Condition
From a total population of about 15,410 tenants for the fiscal year ended September 30, 2023, we selected a statistically valid sample of one monthly subsidy payment for each of 60 selected tenants, and identified fifteen tenants whose HQS inspections were completed past the due dates and seven tenants whose HQS inspection reports were not provided for review.
Cause of Condition
The Authority’s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed.
Effect
The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality.
Questioned Costs
Known questioned costs of $179,377 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 60 participants that totaled $1,550,585 in HAPs to the total HAPs of $385,748,113 for the year, results in likely questioned costs of $44,624,677.
Identification of Repeat Finding
This is a repeat of finding 2022-003 reported for the year ended September 30, 2022.
Recommendation
The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Voucher Cluster
Assistance Listing Number: 14.871 and 14.879
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections)
Classification of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance
Criteria
Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority was required to resume biennial inspections by December 31, 2021. The Authority was required to conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and was required to conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022.
Condition
From a total population of about 15,410 tenants for the fiscal year ended September 30, 2023, we selected a statistically valid sample of one monthly subsidy payment for each of 60 selected tenants, and identified fifteen tenants whose HQS inspections were completed past the due dates and seven tenants whose HQS inspection reports were not provided for review.
Cause of Condition
The Authority’s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed.
Effect
The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality.
Questioned Costs
Known questioned costs of $179,377 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 60 participants that totaled $1,550,585 in HAPs to the total HAPs of $385,748,113 for the year, results in likely questioned costs of $44,624,677.
Identification of Repeat Finding
This is a repeat of finding 2022-003 reported for the year ended September 30, 2022.
Recommendation
The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Voucher Cluster
Assistance Listing Number: 14.871 and 14.879
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections)
Classification of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance
Criteria
Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority was required to resume biennial inspections by December 31, 2021. The Authority was required to conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and was required to conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022.
Condition
From a total population of about 15,410 tenants for the fiscal year ended September 30, 2023, we selected a statistically valid sample of one monthly subsidy payment for each of 60 selected tenants, and identified fifteen tenants whose HQS inspections were completed past the due dates and seven tenants whose HQS inspection reports were not provided for review.
Cause of Condition
The Authority’s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed.
Effect
The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality.
Questioned Costs
Known questioned costs of $179,377 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 60 participants that totaled $1,550,585 in HAPs to the total HAPs of $385,748,113 for the year, results in likely questioned costs of $44,624,677.
Identification of Repeat Finding
This is a repeat of finding 2022-003 reported for the year ended September 30, 2022.
Recommendation
The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-003
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Section 8 Housing Choice Vouchers
Federal Catalog Number: 14.871
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions - HQS Enforcement
Classification of Finding: Significant Deficiency in Internal Control over Compliance
Instance of Noncompliance
Criteria
Pursuant to 24 CFR 982.404(a)(3), the Authority must not make any housing assistance payments (HAP) for a dwelling unit that fails to meet the housing quality standard (HQS), unless the owner corrects the defect within the period specified by the Authority and the Authority verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). Furthermore, 24 CFR 982.404(b)(2) states that if an HQS breach caused by the family is life threatening, the family must correct the defect within no more than 24 hours. For other family-caused defects, the family must correct the defect within no more than 30 calendar days (or any PHA-approved extension).
Condition
Of the total of 3,515 tenants with failed inspections during the fiscal year, we identified three cases in a statistically valid sample of 60 failed inspections in which the Authority did not perform follow-up inspections within the required timeframe to verify identified defects were corrected and/or did not abate HAPs for defects that were not corrected within the required timeframe.
Cause of Condition
The Authority does not have adequate controls in place to ensure that the HQS are being enforced or completed in a timely manner and that HAPs are being properly withheld.
Effect
The Authority is not in compliance with the HQS enforcement requirements, which may result in tenants living in unsafe housing units. In addition, the Authority may be paying HAPs to property owners whose units have inadequate housing quality and may be incorrectly withholding HAPs to landlords who have properly corrected the deficiencies within the required timeframe.
Questioned Costs
Known questioned costs totaled $10,770, which represents HAPs made for months in which the required follow-up inspections were not performed or HAPs were not abated after failed re-inspections.
Identification of Repeat Finding
This is not a repeat finding in the immediate prior audit period.
Recommendation
The Authority should continue to develop procedures and strengthen its internal controls related to HQS enforcement. The Authority should also regularly review the list of failed inspections to verify that units with failed HQS inspections have the housing assistance payments properly withheld and that property owners whose units passed re-inspection are properly paid.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.
Finding Reference: 2023-003
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Section 8 Housing Choice Vouchers
Federal Catalog Number: 14.871
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions - HQS Enforcement
Classification of Finding: Significant Deficiency in Internal Control over Compliance
Instance of Noncompliance
Criteria
Pursuant to 24 CFR 982.404(a)(3), the Authority must not make any housing assistance payments (HAP) for a dwelling unit that fails to meet the housing quality standard (HQS), unless the owner corrects the defect within the period specified by the Authority and the Authority verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). Furthermore, 24 CFR 982.404(b)(2) states that if an HQS breach caused by the family is life threatening, the family must correct the defect within no more than 24 hours. For other family-caused defects, the family must correct the defect within no more than 30 calendar days (or any PHA-approved extension).
Condition
Of the total of 3,515 tenants with failed inspections during the fiscal year, we identified three cases in a statistically valid sample of 60 failed inspections in which the Authority did not perform follow-up inspections within the required timeframe to verify identified defects were corrected and/or did not abate HAPs for defects that were not corrected within the required timeframe.
Cause of Condition
The Authority does not have adequate controls in place to ensure that the HQS are being enforced or completed in a timely manner and that HAPs are being properly withheld.
Effect
The Authority is not in compliance with the HQS enforcement requirements, which may result in tenants living in unsafe housing units. In addition, the Authority may be paying HAPs to property owners whose units have inadequate housing quality and may be incorrectly withholding HAPs to landlords who have properly corrected the deficiencies within the required timeframe.
Questioned Costs
Known questioned costs totaled $10,770, which represents HAPs made for months in which the required follow-up inspections were not performed or HAPs were not abated after failed re-inspections.
Identification of Repeat Finding
This is not a repeat finding in the immediate prior audit period.
Recommendation
The Authority should continue to develop procedures and strengthen its internal controls related to HQS enforcement. The Authority should also regularly review the list of failed inspections to verify that units with failed HQS inspections have the housing assistance payments properly withheld and that property owners whose units passed re-inspection are properly paid.
View of Responsible Officials and Planned Corrective Action
See separately prepared Corrective Action Plan.