Finding SA2019-001: Rent Reasonableness Determination
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR Section 982.507 requires Public Housing Authorities (PHA) that receive Section 8 housing choice vouchers to determine whether the rent paid to the owner is a reasonable rent in comparison to rent for other comparable unassisted units by considering the location, quality, size, unit type and age of the contract unit. The PHA is required to maintain records to document the basis for the determination that rent to owner is a reasonable rent.
Condition: We reviewed sixty Section 8 tenant files for new and existing tenants, and noted six instances in which there were no rent reasonableness certificates to support the respective rent increases in fiscal year 2019 or certificates to support rent over the last three years. Furthermore, we noted one instance in which the tenant’s rental assistance was above the amount determined reasonable through the rent reasonableness determination, however, the Housing Authority did not modify the tenant’s payment accordingly.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.507.
Cause: We understand the missing certificates and unreasonable rent was due to staff turnover and lack of oversight in the Housing Authority during fiscal year 2019.
Identification as a repeat finding: Yes. Since fiscal year 2017.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files. In addition, any unreasonable rent should be adjusted accordingly.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-002: Missing Utility Allowance Forms
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR Section 982.517 requires Public Housing Authorities (PHA) maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised.
Condition: We examined sixty Section 8 tenant files for new and existing tenants, and noted three instances in which there were no utility allowance schedule included in the tenant’s file for fiscal year 2019.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.517.
Cause: It was noted the missing allowance schedules were due to staff oversight.
Identification as a repeat finding: Yes. Since fiscal year 2017.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-003: Annual Housing Quality Standards Inspections
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR Sections 982.158(d) and 982.405(b) requires Public Housing Authorities (PHA) must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report. For inspections that fail the standards, the PHA is required to complete a follow up inspection with the tenants within 24 hours for life-threatening deficiencies and within 30 days for non- life-threatening deficiencies.
Condition: We reviewed sixty Section 8 tenant files for new and existing tenants and noted the following:
• Five instances in which an HQS Inspection checklist was not included in the tenants’ files.
• One instance in which an HQS inspection checklist was in process, however, there was no inspection date or sign off indicating whether inspection was completed.
• One instance in which there was a failed inspection for the tenant, however, there was no documentation of a reinspection.
• Three instances in which the tenant had a failed inspection and a reinspection with an additional fail, and there was no documentation indicating follow up by the Housing Authority.
We also reviewed forty HQS inspections that had failed inspections during fiscal year 2019 and noted the following:
• Eight instances in which the tenant failed the inspection and did not receive a grade of pass until well over the 30 day required timeframe.
• Three instances in which the failed inspection was due to a life threatening deficiency which must be corrected within 24 hours. However, the tenants were not reinspected from 30 days to more than 30 days until after the deficiencies were noted.
• Eight instances in which there was a failed inspection for the unit, however, the Housing Authority did not follow up to re-inspect the unit.
• One instance in which the tenant failed the original inspection and re-inspection. However, the Housing Authority did not follow up with the tenant until a year after.
• One instance in which the tenant failed the original inspection and re-inspection, however, the Housing Authority never followed up with the tenant.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.517(d) and 982.405(b).
Cause: It was noted the missing checklists were due to staff oversight.
Identification as a repeat finding: Yes. Since fiscal 2017 and in 2018.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-004: Incomplete Tenant Files – Income Reexamination
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to maintain up to date files for all new and existing tenants. Files should include all required forms and documentation as stipulated in 24 CFR Section 982.
Condition: We reviewed sixty Section 8 tenant files for new and existing tenants, and noted six instances in which the income reexamination form for fiscal year 2019 was missing from the tenant’s file.
Effect: The Authority is not in compliance with the requirements as stated in 24 CFR Section 982.
Cause: It was noted the missing forms were due to staff oversight.
Identification as a repeat finding: Yes. Since fiscal 2017.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-005: Timeliness and Accuracy of Voucher Payments
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR part 982 requires that monthly housing assistance payments on behalf of tenants to landlords be made in accordance with the tenants’ Housing Assistance Payment (HAP) contract for the Section 8 Housing Choice Vouchers (HCV) program. Payments made should be processed in a timely manner, usually at the beginning of each month and the payments should be made in the correct amount each month in accordance with the HAP contracts for the tenants.
Condition: We tested sixty HCV tenants’ HAPs made to landlords in June 2019 and noted the following:
o Twelve tenants that did not have HAP contract documentation indicating the amount of the HAP contract to support the payments made, that totaled $15,374 for the twelve tenants selected for testing.
o One tenant was paid in the amount of $1,820. However, the payment should have been made in the amount of $1,391.
o One tenant was paid in the amount of $1,525. However, the payment should have been made in the amount of $1,549.
o One tenant was paid in the amount of $1,342. However, the Housing Authority indicated that the tenant was deceased and should not have received rent that month.
o Six tenant files could not be located as noted in finding SA 2019-006. HAP payments to three of the tenants totaled $4,183. No HAP payments were made to the other three tenants and the Authority was not able to explain why.
Effect: When HAPs are not paid timely or correctly, the Authority runs the risk of unpaid contracts and the Authority is not in compliance with the housing payment requirements for the HCV program.
Cause: The above condition was caused by staff turnover and management oversight.
Identification as a repeat finding: Yes. Since fiscal 2017.
Questioned Costs: We question all costs noted above in the total amount of $21,328.
Recommendation: The Authority must develop procedures to ensure that payments are made timely and accurately in accordance with grant requirements.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Authority.
Finding SA2019-006: Missing Tenant Files
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to maintain up to date files for all new and existing tenants. Files should include all required forms and documentation as stipulated in 24 CFR Section 982.
Condition: During our active tenant testing, we noted six tenants of which the Housing Authority did not have any tenant files for the tenants. Therefore, we were unable to verify that the tenants exist or were paid in the proper amounts.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.
Cause: We understand the missing files were due to oversight by the Housing Authority during the transition of the Housing Authority files to the County in 2019.
Questioned Costs: Questioned costs are identified for these files as a part of finding SA 2019-005.
Identification as a repeat finding: Yes, Since fiscal 2017.
Recommendation: The Housing Authority must develop procedures to ensure files exist for all tenants.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-007: Required Reporting
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to file and complete Form HUD-52648, SEMAP Certification – Addendum for Reporting Data for Deconcentration Bonus Indictor as stipulated in 24 CFR Section 985 each fiscal year.
Condition: We noted that the Housing Authority did not file the required Form HUD-52648 during fiscal year 2019.
Effect: The Housing Authority is not in compliance with the reporting requirements as stated in 24 CFR Section 985.
Cause: We understand the report was not filed due to oversight by the Housing Authority during the transition of the Housing Authority program to the County in 2019.
Recommendation: The Housing Authority must develop procedures to ensure all required reports are filed for the program.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-008: Internal Controls
AL number: 14.850 and 14.871
AL Title: Public and Indian Housing, and Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Condition: During our audit, we were unable to obtain an understanding of the internal controls over the federal awards of the Authority, because current Authority staff could not respond to our inquiries about processes and procedures.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide any information regarding the internal controls of the Authority.
Effect: The Housing Authority is not in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Recommendation: The Housing Authority must develop procedures to ensure that there is an internal control environment in compliance with the federal requirements.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-008: Internal Controls
AL number: 14.850 and 14.871
AL Title: Public and Indian Housing, and Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Condition: During our audit, we were unable to obtain an understanding of the internal controls over the federal awards of the Authority, because current Authority staff could not respond to our inquiries about processes and procedures.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide any information regarding the internal controls of the Authority.
Effect: The Housing Authority is not in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Recommendation: The Housing Authority must develop procedures to ensure that there is an internal control environment in compliance with the federal requirements.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-009: Operating Subsidy Payments Supporting Documentation
AL number: 14.850
AL Title: Public and Indian Housing
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR section 990 requires Public Housing Authorities (PHA) to provide operating subsidies to public housing projects and document the specific calculation requirements through HUD Form 52723.
Condition: During our audit, we were unable to obtain sufficient documentation for additional operating subsidy payments made to Easter Hill for Richmond Village I, II, and III in the amount of $179,806 made in fiscal year 2019 that staff indicated were for payments that should have been made in fiscal year 2018. Furthermore, the payments in the amount of $179,806 were not supported by the HUD Form 52723 and therefore, we were unable to determine if the subsidy payments were properly calculated in accordance with 24 CFR 990.
Cause: Due to staffing shortage, operating subsidy payments were delayed for a period and then paid in a lump sum without attaching detailed supporting documents.
Effect: The Housing Authority is not in compliance with the specific calculation requirements of HUD Form 52723 as specified in 24 CFR section 990.
Questioned Costs: We question the costs in the amount of $179,806 noted above.
Recommendation: The Housing Authority must develop procedures to ensure that all operating subsidy payments made are supported by HUD Form 52723 and in accordance with 24 CFR section 990.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-010: Waiting List Documentation
AL number: 14.850
AL Title: Public and Indian Housing
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR section 960 requires Public Housing Authorities (PHA) to maintain waiting lists for public housing. Furthermore, all payments made to tenants should be supported by contracts and proof of payment to the tenants.
Condition: During our audit, the Housing Authority was unable to provide us with a waiting list for the public housing program and therefore, we were unable to verify that the Authority was adhering to the waiting list requirements as outlined in 24 CFR section 960.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide such documentation.
Effect: The Housing Authority is not in compliance with the waiting list documentation requirements under 24 CFR section 960.
Recommendation: The Housing Authority must develop procedures to ensure that waiting list documentation is maintained in accordance with 24 CFR section 960.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-011: Missing Tenant Documents
AL number: 14.850
AL Title: Public and Indian Housing
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR section 960 requires Public Housing Authorities (PHA) that receive public housing funds to remit payment to eligible tenants and to maintain documentation for the payments through a contract.
Condition: We reviewed seventeen public housing files for existing tenants for the month of June 2019 and noted that the Authority did not have documentation of payments clearing the Authority’s bank account. Furthermore, we noted one tenant that should have received utility assistance in the amount of $105 under the program, but the Authority did not remit the assistance payment.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide such documentation.
Effect: The Housing Authority is not in compliance with the payment documentation requirements as stated in 24 CFR section 960.
Recommendation: The Housing Authority must develop procedures to ensure that all public housing assistance provided to eligible tenants is maintained, including proof of payment.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-001: Rent Reasonableness Determination
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR Section 982.507 requires Public Housing Authorities (PHA) that receive Section 8 housing choice vouchers to determine whether the rent paid to the owner is a reasonable rent in comparison to rent for other comparable unassisted units by considering the location, quality, size, unit type and age of the contract unit. The PHA is required to maintain records to document the basis for the determination that rent to owner is a reasonable rent.
Condition: We reviewed sixty Section 8 tenant files for new and existing tenants, and noted six instances in which there were no rent reasonableness certificates to support the respective rent increases in fiscal year 2019 or certificates to support rent over the last three years. Furthermore, we noted one instance in which the tenant’s rental assistance was above the amount determined reasonable through the rent reasonableness determination, however, the Housing Authority did not modify the tenant’s payment accordingly.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.507.
Cause: We understand the missing certificates and unreasonable rent was due to staff turnover and lack of oversight in the Housing Authority during fiscal year 2019.
Identification as a repeat finding: Yes. Since fiscal year 2017.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files. In addition, any unreasonable rent should be adjusted accordingly.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-002: Missing Utility Allowance Forms
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR Section 982.517 requires Public Housing Authorities (PHA) maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised.
Condition: We examined sixty Section 8 tenant files for new and existing tenants, and noted three instances in which there were no utility allowance schedule included in the tenant’s file for fiscal year 2019.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.517.
Cause: It was noted the missing allowance schedules were due to staff oversight.
Identification as a repeat finding: Yes. Since fiscal year 2017.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-003: Annual Housing Quality Standards Inspections
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR Sections 982.158(d) and 982.405(b) requires Public Housing Authorities (PHA) must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report. For inspections that fail the standards, the PHA is required to complete a follow up inspection with the tenants within 24 hours for life-threatening deficiencies and within 30 days for non- life-threatening deficiencies.
Condition: We reviewed sixty Section 8 tenant files for new and existing tenants and noted the following:
• Five instances in which an HQS Inspection checklist was not included in the tenants’ files.
• One instance in which an HQS inspection checklist was in process, however, there was no inspection date or sign off indicating whether inspection was completed.
• One instance in which there was a failed inspection for the tenant, however, there was no documentation of a reinspection.
• Three instances in which the tenant had a failed inspection and a reinspection with an additional fail, and there was no documentation indicating follow up by the Housing Authority.
We also reviewed forty HQS inspections that had failed inspections during fiscal year 2019 and noted the following:
• Eight instances in which the tenant failed the inspection and did not receive a grade of pass until well over the 30 day required timeframe.
• Three instances in which the failed inspection was due to a life threatening deficiency which must be corrected within 24 hours. However, the tenants were not reinspected from 30 days to more than 30 days until after the deficiencies were noted.
• Eight instances in which there was a failed inspection for the unit, however, the Housing Authority did not follow up to re-inspect the unit.
• One instance in which the tenant failed the original inspection and re-inspection. However, the Housing Authority did not follow up with the tenant until a year after.
• One instance in which the tenant failed the original inspection and re-inspection, however, the Housing Authority never followed up with the tenant.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.517(d) and 982.405(b).
Cause: It was noted the missing checklists were due to staff oversight.
Identification as a repeat finding: Yes. Since fiscal 2017 and in 2018.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-004: Incomplete Tenant Files – Income Reexamination
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to maintain up to date files for all new and existing tenants. Files should include all required forms and documentation as stipulated in 24 CFR Section 982.
Condition: We reviewed sixty Section 8 tenant files for new and existing tenants, and noted six instances in which the income reexamination form for fiscal year 2019 was missing from the tenant’s file.
Effect: The Authority is not in compliance with the requirements as stated in 24 CFR Section 982.
Cause: It was noted the missing forms were due to staff oversight.
Identification as a repeat finding: Yes. Since fiscal 2017.
Recommendation: The Housing Authority must develop procedures to ensure required documentation is properly maintained for all tenant files.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-005: Timeliness and Accuracy of Voucher Payments
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR part 982 requires that monthly housing assistance payments on behalf of tenants to landlords be made in accordance with the tenants’ Housing Assistance Payment (HAP) contract for the Section 8 Housing Choice Vouchers (HCV) program. Payments made should be processed in a timely manner, usually at the beginning of each month and the payments should be made in the correct amount each month in accordance with the HAP contracts for the tenants.
Condition: We tested sixty HCV tenants’ HAPs made to landlords in June 2019 and noted the following:
o Twelve tenants that did not have HAP contract documentation indicating the amount of the HAP contract to support the payments made, that totaled $15,374 for the twelve tenants selected for testing.
o One tenant was paid in the amount of $1,820. However, the payment should have been made in the amount of $1,391.
o One tenant was paid in the amount of $1,525. However, the payment should have been made in the amount of $1,549.
o One tenant was paid in the amount of $1,342. However, the Housing Authority indicated that the tenant was deceased and should not have received rent that month.
o Six tenant files could not be located as noted in finding SA 2019-006. HAP payments to three of the tenants totaled $4,183. No HAP payments were made to the other three tenants and the Authority was not able to explain why.
Effect: When HAPs are not paid timely or correctly, the Authority runs the risk of unpaid contracts and the Authority is not in compliance with the housing payment requirements for the HCV program.
Cause: The above condition was caused by staff turnover and management oversight.
Identification as a repeat finding: Yes. Since fiscal 2017.
Questioned Costs: We question all costs noted above in the total amount of $21,328.
Recommendation: The Authority must develop procedures to ensure that payments are made timely and accurately in accordance with grant requirements.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Authority.
Finding SA2019-006: Missing Tenant Files
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to maintain up to date files for all new and existing tenants. Files should include all required forms and documentation as stipulated in 24 CFR Section 982.
Condition: During our active tenant testing, we noted six tenants of which the Housing Authority did not have any tenant files for the tenants. Therefore, we were unable to verify that the tenants exist or were paid in the proper amounts.
Effect: The Housing Authority is not in compliance with the requirements as stated in 24 CFR Section 982.
Cause: We understand the missing files were due to oversight by the Housing Authority during the transition of the Housing Authority files to the County in 2019.
Questioned Costs: Questioned costs are identified for these files as a part of finding SA 2019-005.
Identification as a repeat finding: Yes, Since fiscal 2017.
Recommendation: The Housing Authority must develop procedures to ensure files exist for all tenants.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-007: Required Reporting
AL number: 14.871
AL Title: Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to file and complete Form HUD-52648, SEMAP Certification – Addendum for Reporting Data for Deconcentration Bonus Indictor as stipulated in 24 CFR Section 985 each fiscal year.
Condition: We noted that the Housing Authority did not file the required Form HUD-52648 during fiscal year 2019.
Effect: The Housing Authority is not in compliance with the reporting requirements as stated in 24 CFR Section 985.
Cause: We understand the report was not filed due to oversight by the Housing Authority during the transition of the Housing Authority program to the County in 2019.
Recommendation: The Housing Authority must develop procedures to ensure all required reports are filed for the program.
Since the Housing Authority transferred the Housing Choice Vouchers (HCV Section 8) program to the Housing Authority of the County of Contra Costa (HACCC) on July 1, 2019, the Housing Authority should work with the HACCC to determine how to address the recommendation.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-008: Internal Controls
AL number: 14.850 and 14.871
AL Title: Public and Indian Housing, and Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Condition: During our audit, we were unable to obtain an understanding of the internal controls over the federal awards of the Authority, because current Authority staff could not respond to our inquiries about processes and procedures.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide any information regarding the internal controls of the Authority.
Effect: The Housing Authority is not in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Recommendation: The Housing Authority must develop procedures to ensure that there is an internal control environment in compliance with the federal requirements.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-008: Internal Controls
AL number: 14.850 and 14.871
AL Title: Public and Indian Housing, and Housing Voucher Cluster - Section 8 Housing Choice Vouchers
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: Public Housing Authorities (PHA) are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Condition: During our audit, we were unable to obtain an understanding of the internal controls over the federal awards of the Authority, because current Authority staff could not respond to our inquiries about processes and procedures.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide any information regarding the internal controls of the Authority.
Effect: The Housing Authority is not in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in CFR 200.303.
Recommendation: The Housing Authority must develop procedures to ensure that there is an internal control environment in compliance with the federal requirements.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-009: Operating Subsidy Payments Supporting Documentation
AL number: 14.850
AL Title: Public and Indian Housing
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR section 990 requires Public Housing Authorities (PHA) to provide operating subsidies to public housing projects and document the specific calculation requirements through HUD Form 52723.
Condition: During our audit, we were unable to obtain sufficient documentation for additional operating subsidy payments made to Easter Hill for Richmond Village I, II, and III in the amount of $179,806 made in fiscal year 2019 that staff indicated were for payments that should have been made in fiscal year 2018. Furthermore, the payments in the amount of $179,806 were not supported by the HUD Form 52723 and therefore, we were unable to determine if the subsidy payments were properly calculated in accordance with 24 CFR 990.
Cause: Due to staffing shortage, operating subsidy payments were delayed for a period and then paid in a lump sum without attaching detailed supporting documents.
Effect: The Housing Authority is not in compliance with the specific calculation requirements of HUD Form 52723 as specified in 24 CFR section 990.
Questioned Costs: We question the costs in the amount of $179,806 noted above.
Recommendation: The Housing Authority must develop procedures to ensure that all operating subsidy payments made are supported by HUD Form 52723 and in accordance with 24 CFR section 990.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-010: Waiting List Documentation
AL number: 14.850
AL Title: Public and Indian Housing
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR section 960 requires Public Housing Authorities (PHA) to maintain waiting lists for public housing. Furthermore, all payments made to tenants should be supported by contracts and proof of payment to the tenants.
Condition: During our audit, the Housing Authority was unable to provide us with a waiting list for the public housing program and therefore, we were unable to verify that the Authority was adhering to the waiting list requirements as outlined in 24 CFR section 960.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide such documentation.
Effect: The Housing Authority is not in compliance with the waiting list documentation requirements under 24 CFR section 960.
Recommendation: The Housing Authority must develop procedures to ensure that waiting list documentation is maintained in accordance with 24 CFR section 960.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.
Finding SA2019-011: Missing Tenant Documents
AL number: 14.850
AL Title: Public and Indian Housing
Name of Federal Agency: Department of Housing and Urban Development
Federal Award Identification number and year: CA010 (2019)
Criteria: 24 CFR section 960 requires Public Housing Authorities (PHA) that receive public housing funds to remit payment to eligible tenants and to maintain documentation for the payments through a contract.
Condition: We reviewed seventeen public housing files for existing tenants for the month of June 2019 and noted that the Authority did not have documentation of payments clearing the Authority’s bank account. Furthermore, we noted one tenant that should have received utility assistance in the amount of $105 under the program, but the Authority did not remit the assistance payment.
Cause: We understand that the staff overseeing the federal awards during fiscal year 2019 are no longer with the Authority, and therefore, the staff overseeing the federal awards subsequent to the fiscal year were unable to provide such documentation.
Effect: The Housing Authority is not in compliance with the payment documentation requirements as stated in 24 CFR section 960.
Recommendation: The Housing Authority must develop procedures to ensure that all public housing assistance provided to eligible tenants is maintained, including proof of payment.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the Housing Authority.