Finding 2024-001 - Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed a sample of sixty-five (65) tenant files, which included both Public Housing and Housing Choice Voucher participants. Of these, eight (8) files were found to be noncompliant, representing approximately 12% of the sample. Specifically, three (3) files lacked the required Enterprise Income Verification (EIV) documentation, and five (5) files relied on tenant self-declarations for income verification without documenting efforts to obtain the preferred third-party verification.
The cause of this noncompliance, as discussed with management, ls attributed to staff vacancies and challenges in hiring and retaining qualified personnel. This staffing issue has likely contributed to the oversight and failure to consistently adhere to income verification requirements.
Criteria: The Code of Federal Regulations, the Housing Authority's Administrative Plan, Admissions & Continued Occupancy Policy, and MTW Plan, and specific HUD guidelines in documenting and maintaining Public Housing and Housing Choice Voucher tenant files.
Effect: The absence of EIV documentation and reliance on tenant self-declaration without adequate third party verification efforts may result in inaccurate income assessments, potentially affecting eligibility and rent calculations.
Recommendation: we recommend that the PHA enhance quality control review procedures to ensure all tenant files contain the required EIV documentation and that efforts to obtain third-party verification of income are consistently documented.
Questioned Costs: None·
Repeat Finding: No
Was sampling statistically valid? Yes
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.
Finding 2024-002 - Moving to Work Demonstration ALN 14.881- Procurement - Formal Competitive Requirements - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed the contracts associated with the largest purchases of the fiscal year to determine if the procurement procedures followed the Housing Authority's Procurement Policy and Federal Regulations. We found that large PHA-wide purchases for roofing materials and labor were being Improperly split into smaller contracts by individual property. The Authority gathered quotes for all properties at the same time under small purchase procedures, though the aggregate contract costs exceeded the small purchase ceiling. We feel these projects met the conditions for sealed bidding to be feasible as outlined in 2 CFR §200.320(b){l).
Additionally, the Procurement Policy was last updated and approved by the Board 1n 2003. Failure to consistently enforce the requirements for competitive procurement methods for larger contracts may have been driven by a lack of oversight or understanding of the regulatory requirements.
Criteria: The Code of Federal Regulations and the Housing Authority's Procurement Policy.
Effect: Circumventing the competitive procurement process potentially leads to higher costs, lack of transparency, and limited competition. This practice undermines the integrity of the procurement process and may result in the inefficient use of federal funds, violating HUD's procurement standards.
Recommendation: We recommend that the PHA review its procurement policies and training to ensure that all large purchases are properly identified and handled through competitive procurement methods, In compliance with applicable regulations. The PHA should also implement controls to prevent the improper splitting of contracts in the future.
Questioned Costs: None
Repeat Finding: No
Was sampling statistically valid? No
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.
Finding 2024-002 - Moving to Work Demonstration ALN 14.881- Procurement - Formal Competitive Requirements - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed the contracts associated with the largest purchases of the fiscal year to determine if the procurement procedures followed the Housing Authority's Procurement Policy and Federal Regulations. We found that large PHA-wide purchases for roofing materials and labor were being Improperly split into smaller contracts by individual property. The Authority gathered quotes for all properties at the same time under small purchase procedures, though the aggregate contract costs exceeded the small purchase ceiling. We feel these projects met the conditions for sealed bidding to be feasible as outlined in 2 CFR §200.320(b){l).
Additionally, the Procurement Policy was last updated and approved by the Board 1n 2003. Failure to consistently enforce the requirements for competitive procurement methods for larger contracts may have been driven by a lack of oversight or understanding of the regulatory requirements.
Criteria: The Code of Federal Regulations and the Housing Authority's Procurement Policy.
Effect: Circumventing the competitive procurement process potentially leads to higher costs, lack of transparency, and limited competition. This practice undermines the integrity of the procurement process and may result in the inefficient use of federal funds, violating HUD's procurement standards.
Recommendation: We recommend that the PHA review its procurement policies and training to ensure that all large purchases are properly identified and handled through competitive procurement methods, In compliance with applicable regulations. The PHA should also implement controls to prevent the improper splitting of contracts in the future.
Questioned Costs: None
Repeat Finding: No
Was sampling statistically valid? No
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.
Finding 2024-001 - Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed a sample of sixty-five (65) tenant files, which included both Public Housing and Housing Choice Voucher participants. Of these, eight (8) files were found to be noncompliant, representing approximately 12% of the sample. Specifically, three (3) files lacked the required Enterprise Income Verification (EIV) documentation, and five (5) files relied on tenant self-declarations for income verification without documenting efforts to obtain the preferred third-party verification.
The cause of this noncompliance, as discussed with management, ls attributed to staff vacancies and challenges in hiring and retaining qualified personnel. This staffing issue has likely contributed to the oversight and failure to consistently adhere to income verification requirements.
Criteria: The Code of Federal Regulations, the Housing Authority's Administrative Plan, Admissions & Continued Occupancy Policy, and MTW Plan, and specific HUD guidelines in documenting and maintaining Public Housing and Housing Choice Voucher tenant files.
Effect: The absence of EIV documentation and reliance on tenant self-declaration without adequate third party verification efforts may result in inaccurate income assessments, potentially affecting eligibility and rent calculations.
Recommendation: we recommend that the PHA enhance quality control review procedures to ensure all tenant files contain the required EIV documentation and that efforts to obtain third-party verification of income are consistently documented.
Questioned Costs: None·
Repeat Finding: No
Was sampling statistically valid? Yes
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.
Finding 2024-001 - Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed a sample of sixty-five (65) tenant files, which included both Public Housing and Housing Choice Voucher participants. Of these, eight (8) files were found to be noncompliant, representing approximately 12% of the sample. Specifically, three (3) files lacked the required Enterprise Income Verification (EIV) documentation, and five (5) files relied on tenant self-declarations for income verification without documenting efforts to obtain the preferred third-party verification.
The cause of this noncompliance, as discussed with management, ls attributed to staff vacancies and challenges in hiring and retaining qualified personnel. This staffing issue has likely contributed to the oversight and failure to consistently adhere to income verification requirements.
Criteria: The Code of Federal Regulations, the Housing Authority's Administrative Plan, Admissions & Continued Occupancy Policy, and MTW Plan, and specific HUD guidelines in documenting and maintaining Public Housing and Housing Choice Voucher tenant files.
Effect: The absence of EIV documentation and reliance on tenant self-declaration without adequate third party verification efforts may result in inaccurate income assessments, potentially affecting eligibility and rent calculations.
Recommendation: we recommend that the PHA enhance quality control review procedures to ensure all tenant files contain the required EIV documentation and that efforts to obtain third-party verification of income are consistently documented.
Questioned Costs: None·
Repeat Finding: No
Was sampling statistically valid? Yes
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.
Finding 2024-002 - Moving to Work Demonstration ALN 14.881- Procurement - Formal Competitive Requirements - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed the contracts associated with the largest purchases of the fiscal year to determine if the procurement procedures followed the Housing Authority's Procurement Policy and Federal Regulations. We found that large PHA-wide purchases for roofing materials and labor were being Improperly split into smaller contracts by individual property. The Authority gathered quotes for all properties at the same time under small purchase procedures, though the aggregate contract costs exceeded the small purchase ceiling. We feel these projects met the conditions for sealed bidding to be feasible as outlined in 2 CFR §200.320(b){l).
Additionally, the Procurement Policy was last updated and approved by the Board 1n 2003. Failure to consistently enforce the requirements for competitive procurement methods for larger contracts may have been driven by a lack of oversight or understanding of the regulatory requirements.
Criteria: The Code of Federal Regulations and the Housing Authority's Procurement Policy.
Effect: Circumventing the competitive procurement process potentially leads to higher costs, lack of transparency, and limited competition. This practice undermines the integrity of the procurement process and may result in the inefficient use of federal funds, violating HUD's procurement standards.
Recommendation: We recommend that the PHA review its procurement policies and training to ensure that all large purchases are properly identified and handled through competitive procurement methods, In compliance with applicable regulations. The PHA should also implement controls to prevent the improper splitting of contracts in the future.
Questioned Costs: None
Repeat Finding: No
Was sampling statistically valid? No
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.
Finding 2024-002 - Moving to Work Demonstration ALN 14.881- Procurement - Formal Competitive Requirements - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed the contracts associated with the largest purchases of the fiscal year to determine if the procurement procedures followed the Housing Authority's Procurement Policy and Federal Regulations. We found that large PHA-wide purchases for roofing materials and labor were being Improperly split into smaller contracts by individual property. The Authority gathered quotes for all properties at the same time under small purchase procedures, though the aggregate contract costs exceeded the small purchase ceiling. We feel these projects met the conditions for sealed bidding to be feasible as outlined in 2 CFR §200.320(b){l).
Additionally, the Procurement Policy was last updated and approved by the Board 1n 2003. Failure to consistently enforce the requirements for competitive procurement methods for larger contracts may have been driven by a lack of oversight or understanding of the regulatory requirements.
Criteria: The Code of Federal Regulations and the Housing Authority's Procurement Policy.
Effect: Circumventing the competitive procurement process potentially leads to higher costs, lack of transparency, and limited competition. This practice undermines the integrity of the procurement process and may result in the inefficient use of federal funds, violating HUD's procurement standards.
Recommendation: We recommend that the PHA review its procurement policies and training to ensure that all large purchases are properly identified and handled through competitive procurement methods, In compliance with applicable regulations. The PHA should also implement controls to prevent the improper splitting of contracts in the future.
Questioned Costs: None
Repeat Finding: No
Was sampling statistically valid? No
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.
Finding 2024-001 - Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility - Noncompliance & Significant Deficiency
Condition & Cause: We reviewed a sample of sixty-five (65) tenant files, which included both Public Housing and Housing Choice Voucher participants. Of these, eight (8) files were found to be noncompliant, representing approximately 12% of the sample. Specifically, three (3) files lacked the required Enterprise Income Verification (EIV) documentation, and five (5) files relied on tenant self-declarations for income verification without documenting efforts to obtain the preferred third-party verification.
The cause of this noncompliance, as discussed with management, ls attributed to staff vacancies and challenges in hiring and retaining qualified personnel. This staffing issue has likely contributed to the oversight and failure to consistently adhere to income verification requirements.
Criteria: The Code of Federal Regulations, the Housing Authority's Administrative Plan, Admissions & Continued Occupancy Policy, and MTW Plan, and specific HUD guidelines in documenting and maintaining Public Housing and Housing Choice Voucher tenant files.
Effect: The absence of EIV documentation and reliance on tenant self-declaration without adequate third party verification efforts may result in inaccurate income assessments, potentially affecting eligibility and rent calculations.
Recommendation: we recommend that the PHA enhance quality control review procedures to ensure all tenant files contain the required EIV documentation and that efforts to obtain third-party verification of income are consistently documented.
Questioned Costs: None·
Repeat Finding: No
Was sampling statistically valid? Yes
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.