2024 – 001
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024 Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must do the following:
As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA 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).
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).
Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 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 7 out of 60 files tested for eligibility requirements:
Income support was not provided or the support did not agree to the recertification for 5 samples.
Expense support was not provided or the support did not agree to the recertification for 3 samples.
The Housing assistance payment (HAP) was not properly calculated due to income and/or expense amounts not being supported for 7 samples.
Signed releases of information (HUD-9886 and general release forms) were not provided for 1 sample.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, see prior year finding 2023-002.
Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Selection from the Waiting List (New Tenants)
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and Authority documentation must show that the Authority follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the Authority notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for new tenants.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 3 out of 60 files tested for new tenants:
The selection letter was missing for 2 samples.
A copy of the signed voucher was not provided for 2 samples.
The housing assistance payment contract was not duly executed or available for review for 3 files.
The original application date and/or admission application date was not provided for 2 samples.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with new tenant admission requirements.
Repeat Finding: Yes, see prior year finding 2023-003.
Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
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 (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for reasonable rent requirements.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 1 out of 60 files tested for rent increases. The reasonable rent determination was not completed prior to the effective date.
Exceptions were noted in 3 of 60 files tested for rent reasonableness of new tenants:
Documentation was not provided for 2 samples
The approved rent was lower than the effective rent for 1 sample
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, see prior year finding 2023-004.
Recommendation: We recommend the Authority review their process and internal controls for rent reasonableness to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Enforcement
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
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: $7,411
Context: Exceptions were noted in 15 out of 60 failed inspections:
The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 4 out of 60 failed inspections.
The Authority did not properly abate HAP for 14 out of 60 failed inspections.
The Authority failed to enforce family obligations for 1 out of 60 failed inspections.
The Authority failed to provide notice of failed inspection to landlord and tenant for 1 out of 60 failed inspections.
The Authority failed to provide copy of the passed inspection 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, see prior year finding 2023-005.
Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). 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.
2024 – 005
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Inspections
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
Criteria or Specific Requirement: The Authority must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)).
Condition: The Authority did inspect units timely or maintain proper inspection documentation.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 11 out of 60 units tested for annual HQS:
9 instances where the Authority failed to conduct the inspection timely.
2 instances where no information was provided.
Exceptions were noted in 1 out of 14 quality control re-inspections. The re-inspection was not completed within 90 days of the original inspection.
Cause: The Authority did not inspect units timely.
Effect: The Authority is not in compliance with HQS inspection requirements
Repeat Finding: No
Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are performed timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 001
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024 Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must do the following:
As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA 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).
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).
Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 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 7 out of 60 files tested for eligibility requirements:
Income support was not provided or the support did not agree to the recertification for 5 samples.
Expense support was not provided or the support did not agree to the recertification for 3 samples.
The Housing assistance payment (HAP) was not properly calculated due to income and/or expense amounts not being supported for 7 samples.
Signed releases of information (HUD-9886 and general release forms) were not provided for 1 sample.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, see prior year finding 2023-002.
Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Selection from the Waiting List (New Tenants)
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and Authority documentation must show that the Authority follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the Authority notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for new tenants.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 3 out of 60 files tested for new tenants:
The selection letter was missing for 2 samples.
A copy of the signed voucher was not provided for 2 samples.
The housing assistance payment contract was not duly executed or available for review for 3 files.
The original application date and/or admission application date was not provided for 2 samples.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with new tenant admission requirements.
Repeat Finding: Yes, see prior year finding 2023-003.
Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
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 (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for reasonable rent requirements.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 1 out of 60 files tested for rent increases. The reasonable rent determination was not completed prior to the effective date.
Exceptions were noted in 3 of 60 files tested for rent reasonableness of new tenants:
Documentation was not provided for 2 samples
The approved rent was lower than the effective rent for 1 sample
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, see prior year finding 2023-004.
Recommendation: We recommend the Authority review their process and internal controls for rent reasonableness to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Enforcement
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
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: $7,411
Context: Exceptions were noted in 15 out of 60 failed inspections:
The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 4 out of 60 failed inspections.
The Authority did not properly abate HAP for 14 out of 60 failed inspections.
The Authority failed to enforce family obligations for 1 out of 60 failed inspections.
The Authority failed to provide notice of failed inspection to landlord and tenant for 1 out of 60 failed inspections.
The Authority failed to provide copy of the passed inspection 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, see prior year finding 2023-005.
Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). 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.
2024 – 005
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Inspections
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
Criteria or Specific Requirement: The Authority must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)).
Condition: The Authority did inspect units timely or maintain proper inspection documentation.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 11 out of 60 units tested for annual HQS:
9 instances where the Authority failed to conduct the inspection timely.
2 instances where no information was provided.
Exceptions were noted in 1 out of 14 quality control re-inspections. The re-inspection was not completed within 90 days of the original inspection.
Cause: The Authority did not inspect units timely.
Effect: The Authority is not in compliance with HQS inspection requirements
Repeat Finding: No
Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are performed timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 001
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024 Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must do the following:
As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA 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).
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).
Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 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 7 out of 60 files tested for eligibility requirements:
Income support was not provided or the support did not agree to the recertification for 5 samples.
Expense support was not provided or the support did not agree to the recertification for 3 samples.
The Housing assistance payment (HAP) was not properly calculated due to income and/or expense amounts not being supported for 7 samples.
Signed releases of information (HUD-9886 and general release forms) were not provided for 1 sample.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, see prior year finding 2023-002.
Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Selection from the Waiting List (New Tenants)
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and Authority documentation must show that the Authority follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the Authority notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for new tenants.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 3 out of 60 files tested for new tenants:
The selection letter was missing for 2 samples.
A copy of the signed voucher was not provided for 2 samples.
The housing assistance payment contract was not duly executed or available for review for 3 files.
The original application date and/or admission application date was not provided for 2 samples.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with new tenant admission requirements.
Repeat Finding: Yes, see prior year finding 2023-003.
Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
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 (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for reasonable rent requirements.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 1 out of 60 files tested for rent increases. The reasonable rent determination was not completed prior to the effective date.
Exceptions were noted in 3 of 60 files tested for rent reasonableness of new tenants:
Documentation was not provided for 2 samples
The approved rent was lower than the effective rent for 1 sample
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, see prior year finding 2023-004.
Recommendation: We recommend the Authority review their process and internal controls for rent reasonableness to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Enforcement
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
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: $7,411
Context: Exceptions were noted in 15 out of 60 failed inspections:
The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 4 out of 60 failed inspections.
The Authority did not properly abate HAP for 14 out of 60 failed inspections.
The Authority failed to enforce family obligations for 1 out of 60 failed inspections.
The Authority failed to provide notice of failed inspection to landlord and tenant for 1 out of 60 failed inspections.
The Authority failed to provide copy of the passed inspection 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, see prior year finding 2023-005.
Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). 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.
2024 – 005
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Inspections
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
Criteria or Specific Requirement: The Authority must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)).
Condition: The Authority did inspect units timely or maintain proper inspection documentation.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 11 out of 60 units tested for annual HQS:
9 instances where the Authority failed to conduct the inspection timely.
2 instances where no information was provided.
Exceptions were noted in 1 out of 14 quality control re-inspections. The re-inspection was not completed within 90 days of the original inspection.
Cause: The Authority did not inspect units timely.
Effect: The Authority is not in compliance with HQS inspection requirements
Repeat Finding: No
Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are performed timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 001
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024 Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must do the following:
As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA 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).
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).
Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 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 7 out of 60 files tested for eligibility requirements:
Income support was not provided or the support did not agree to the recertification for 5 samples.
Expense support was not provided or the support did not agree to the recertification for 3 samples.
The Housing assistance payment (HAP) was not properly calculated due to income and/or expense amounts not being supported for 7 samples.
Signed releases of information (HUD-9886 and general release forms) were not provided for 1 sample.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with eligibility requirements.
Repeat Finding: Yes, see prior year finding 2023-002.
Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 002
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Selection from the Waiting List (New Tenants)
Type of Finding: Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and Authority documentation must show that the Authority follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the Authority notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for new tenants.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 3 out of 60 files tested for new tenants:
The selection letter was missing for 2 samples.
A copy of the signed voucher was not provided for 2 samples.
The housing assistance payment contract was not duly executed or available for review for 3 files.
The original application date and/or admission application date was not provided for 2 samples.
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with new tenant admission requirements.
Repeat Finding: Yes, see prior year finding 2023-003.
Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 003
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO - 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – Reasonable Rent
Type of Finding: Significant Deficiency in Internal Control over Compliance
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 (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507).
Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for reasonable rent requirements.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 1 out of 60 files tested for rent increases. The reasonable rent determination was not completed prior to the effective date.
Exceptions were noted in 3 of 60 files tested for rent reasonableness of new tenants:
Documentation was not provided for 2 samples
The approved rent was lower than the effective rent for 1 sample
Cause: The Authority did not follow the established procedures in its Housing Choice Voucher Administrative Plan.
Effect: The Authority is not in compliance with rent reasonableness requirements.
Repeat Finding: Yes, see prior year finding 2023-004.
Recommendation: We recommend the Authority review their process and internal controls for rent reasonableness to ensure compliance with HUD requirements and their administrative plan.
Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Enforcement
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
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: $7,411
Context: Exceptions were noted in 15 out of 60 failed inspections:
The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 4 out of 60 failed inspections.
The Authority did not properly abate HAP for 14 out of 60 failed inspections.
The Authority failed to enforce family obligations for 1 out of 60 failed inspections.
The Authority failed to provide notice of failed inspection to landlord and tenant for 1 out of 60 failed inspections.
The Authority failed to provide copy of the passed inspection 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, see prior year finding 2023-005.
Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). 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.
2024 – 005
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Award Identification Number and Year: MD015VO – 2024
Award Period: July 1, 2023 – June 30, 2024
Compliance Requirement: Special Tests and Provisions – HQS Inspections
Type of Finding: Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
Criteria or Specific Requirement: The Authority must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)).
Condition: The Authority did inspect units timely or maintain proper inspection documentation.
Questioned Costs: Unable to determine.
Context: Exceptions were noted in 11 out of 60 units tested for annual HQS:
9 instances where the Authority failed to conduct the inspection timely.
2 instances where no information was provided.
Exceptions were noted in 1 out of 14 quality control re-inspections. The re-inspection was not completed within 90 days of the original inspection.
Cause: The Authority did not inspect units timely.
Effect: The Authority is not in compliance with HQS inspection requirements
Repeat Finding: No
Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are performed timely.
Views of Responsible Officials: There is no disagreement with the audit finding.