2024-001 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream – Vouchers CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567.
o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe.
• 1 tenant file had the following errors:
o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
o The tenant did not sign and date the Form 9886.
• 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886.
• 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023.
• 1 tenant file error where a member of the household over 18 years old did not sign Form 9886.
• 1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.
• 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount.
• 1 tenant file error where there was no EIV form for the recertification period.
• 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030:
o An incorrect utility allowance was reported on the Form 50058.
o Income support was not reported correctly on the Form 50058.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen.
o Support for tenant’s pension income was over 12 months old.
• 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-001 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream – Vouchers CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567.
o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe.
• 1 tenant file had the following errors:
o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
o The tenant did not sign and date the Form 9886.
• 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886.
• 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023.
• 1 tenant file error where a member of the household over 18 years old did not sign Form 9886.
• 1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.
• 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount.
• 1 tenant file error where there was no EIV form for the recertification period.
• 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030:
o An incorrect utility allowance was reported on the Form 50058.
o Income support was not reported correctly on the Form 50058.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen.
o Support for tenant’s pension income was over 12 months old.
• 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-001 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream – Vouchers CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567.
o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe.
• 1 tenant file had the following errors:
o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
o The tenant did not sign and date the Form 9886.
• 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886.
• 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023.
• 1 tenant file error where a member of the household over 18 years old did not sign Form 9886.
• 1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.
• 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount.
• 1 tenant file error where there was no EIV form for the recertification period.
• 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030:
o An incorrect utility allowance was reported on the Form 50058.
o Income support was not reported correctly on the Form 50058.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen.
o Support for tenant’s pension income was over 12 months old.
• 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-002 Special Tests and Provisions – Selection from the Waiting List
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022)
Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows:
• 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program.
• 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained).
• 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058.
• 1 new admission where the Authority could not provide the tenant’s voucher.
Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program.
Questioned Costs: None.
Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-002 Special Tests and Provisions – Selection from the Waiting List
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022)
Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows:
• 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program.
• 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained).
• 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058.
• 1 new admission where the Authority could not provide the tenant’s voucher.
Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program.
Questioned Costs: None.
Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-002 Special Tests and Provisions – Selection from the Waiting List
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022)
Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows:
• 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program.
• 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained).
• 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058.
• 1 new admission where the Authority could not provide the tenant’s voucher.
Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program.
Questioned Costs: None.
Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-003 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income
Public and Indian Housing Program – CFDA 14.850
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-004 from March 31, 2023 (originally reported as finding 2022-005 from March 31, 2022)
Criteria: The Authority receive invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period.
Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion.
Cause: Former employees of the Authority did not retain the utility ledger.
Effect: The Authority did not retain the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding.
Questioned Cost: None
Recommendation: The Authority should retain the utility ledger for each fiscal year under audit.
Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to retain the utility ledger. We will retain the utility ledger for each fiscal year under audit.
2024-001 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream – Vouchers CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567.
o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe.
• 1 tenant file had the following errors:
o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
o The tenant did not sign and date the Form 9886.
• 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886.
• 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023.
• 1 tenant file error where a member of the household over 18 years old did not sign Form 9886.
• 1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.
• 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount.
• 1 tenant file error where there was no EIV form for the recertification period.
• 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030:
o An incorrect utility allowance was reported on the Form 50058.
o Income support was not reported correctly on the Form 50058.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen.
o Support for tenant’s pension income was over 12 months old.
• 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-001 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream – Vouchers CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567.
o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe.
• 1 tenant file had the following errors:
o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
o The tenant did not sign and date the Form 9886.
• 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886.
• 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023.
• 1 tenant file error where a member of the household over 18 years old did not sign Form 9886.
• 1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.
• 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount.
• 1 tenant file error where there was no EIV form for the recertification period.
• 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030:
o An incorrect utility allowance was reported on the Form 50058.
o Income support was not reported correctly on the Form 50058.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen.
o Support for tenant’s pension income was over 12 months old.
• 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-001 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream – Vouchers CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567.
o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe.
• 1 tenant file had the following errors:
o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
o The tenant did not sign and date the Form 9886.
• 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886.
• 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023.
• 1 tenant file error where a member of the household over 18 years old did not sign Form 9886.
• 1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.
• 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount.
• 1 tenant file error where there was no EIV form for the recertification period.
• 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030:
o An incorrect utility allowance was reported on the Form 50058.
o Income support was not reported correctly on the Form 50058.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen.
o Support for tenant’s pension income was over 12 months old.
• 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-002 Special Tests and Provisions – Selection from the Waiting List
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022)
Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows:
• 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program.
• 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained).
• 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058.
• 1 new admission where the Authority could not provide the tenant’s voucher.
Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program.
Questioned Costs: None.
Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-002 Special Tests and Provisions – Selection from the Waiting List
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022)
Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows:
• 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program.
• 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained).
• 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058.
• 1 new admission where the Authority could not provide the tenant’s voucher.
Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program.
Questioned Costs: None.
Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-002 Special Tests and Provisions – Selection from the Waiting List
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022)
Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows:
• 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program.
• 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained).
• 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058.
• 1 new admission where the Authority could not provide the tenant’s voucher.
Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program.
Questioned Costs: None.
Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.
2024-003 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income
Public and Indian Housing Program – CFDA 14.850
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2023-004 from March 31, 2023 (originally reported as finding 2022-005 from March 31, 2022)
Criteria: The Authority receive invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period.
Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion.
Cause: Former employees of the Authority did not retain the utility ledger.
Effect: The Authority did not retain the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding.
Questioned Cost: None
Recommendation: The Authority should retain the utility ledger for each fiscal year under audit.
Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to retain the utility ledger. We will retain the utility ledger for each fiscal year under audit.