Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Eligibility
Type of Finding: • Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516).
For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516).
The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, finding 2022-001.
Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908).
Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908.
Questioned costs: Unable to determine.
Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system.
Effect: The Authority is not in compliance with PIC reporting requirements.
Repeat Finding: Yes, finding 2022-002.
Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding:Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, finding 2022-004.
Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding: Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404).
Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs.
Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections.
Cause: The Authority did not reinspect or abate units timely.
Effect: The Authority is not in compliance with HQS enforcement requirements.
Repeat Finding: Yes, finding 2022-005.
Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Eligibility
Type of Finding: • Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516).
For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516).
The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, finding 2022-001.
Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908).
Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908.
Questioned costs: Unable to determine.
Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system.
Effect: The Authority is not in compliance with PIC reporting requirements.
Repeat Finding: Yes, finding 2022-002.
Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding:Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, finding 2022-004.
Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding: Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404).
Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs.
Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections.
Cause: The Authority did not reinspect or abate units timely.
Effect: The Authority is not in compliance with HQS enforcement requirements.
Repeat Finding: Yes, finding 2022-005.
Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Eligibility
Type of Finding: • Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516).
For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516).
The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, finding 2022-001.
Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908).
Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908.
Questioned costs: Unable to determine.
Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system.
Effect: The Authority is not in compliance with PIC reporting requirements.
Repeat Finding: Yes, finding 2022-002.
Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding:Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, finding 2022-004.
Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding: Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404).
Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs.
Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections.
Cause: The Authority did not reinspect or abate units timely.
Effect: The Authority is not in compliance with HQS enforcement requirements.
Repeat Finding: Yes, finding 2022-005.
Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Eligibility
Type of Finding: • Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516).
For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516).
The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, finding 2022-001.
Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908).
Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908.
Questioned costs: Unable to determine.
Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system.
Effect: The Authority is not in compliance with PIC reporting requirements.
Repeat Finding: Yes, finding 2022-002.
Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding:Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, finding 2022-004.
Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding: Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404).
Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs.
Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections.
Cause: The Authority did not reinspect or abate units timely.
Effect: The Authority is not in compliance with HQS enforcement requirements.
Repeat Finding: Yes, finding 2022-005.
Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Eligibility
Type of Finding: • Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516).
For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516).
The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, finding 2022-001.
Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908).
Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908.
Questioned costs: Unable to determine.
Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system.
Effect: The Authority is not in compliance with PIC reporting requirements.
Repeat Finding: Yes, finding 2022-002.
Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding:Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, finding 2022-004.
Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding: Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404).
Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs.
Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections.
Cause: The Authority did not reinspect or abate units timely.
Effect: The Authority is not in compliance with HQS enforcement requirements.
Repeat Finding: Yes, finding 2022-005.
Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Eligibility
Type of Finding: • Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516).
For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516).
The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, finding 2022-001.
Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting
Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908).
Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908.
Questioned costs: Unable to determine.
Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system.
Effect: The Authority is not in compliance with PIC reporting requirements.
Repeat Finding: Yes, finding 2022-002.
Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding:Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements.
Questioned costs: Unable to determine.
Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, finding 2022-004.
Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879
Federal Award Identification Number and Year: MO002VO - 2023
Award Period: January 1, 2023 – December 31, 2023
Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement
Type of Finding: Significant Deficiency in Internal Control over Compliance
Type of Finding: Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404).
Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs.
Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections.
Cause: The Authority did not reinspect or abate units timely.
Effect: The Authority is not in compliance with HQS enforcement requirements.
Repeat Finding: Yes, finding 2022-005.
Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe.
Views of responsible officials: There is no disagreement with the audit finding.