Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD 52681-B report is required to be submitted monthly in HUD’s most current automated system.
Condition: Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD.
Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD 52681-B report is required to be submitted monthly in HUD’s most current automated system.
Condition: Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD.
Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD 52681-B report is required to be submitted monthly in HUD’s most current automated system.
Condition: Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD.
Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement E., Eligibility, condition of admission or continued occupancy is required to obtain necessary information from tenant and (or) other family members and review the necessary information by program supervisor or program manager.
Condition: Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing.
Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement E., Eligibility, condition of admission or continued occupancy is required to obtain necessary information from tenant and (or) other family members and review the necessary information by program supervisor or program manager.
Condition: Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing.
Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement E., Eligibility, condition of admission or continued occupancy is required to obtain necessary information from tenant and (or) other family members and review the necessary information by program supervisor or program manager.
Condition: Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing.
Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.2., Reasonable Rent, requires the County to conduct a reasonable rent analysis when tenant is admitted to a new unit.
Condition: Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.2., Reasonable Rent, requires the County to conduct a reasonable rent analysis when tenant is admitted to a new unit.
Condition: Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.2., Reasonable Rent, requires the County to conduct a reasonable rent analysis when tenant is admitted to a new unit.
Condition: Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard. Per the Federal Register announcement in May 2023, HUD extended the compliance date for HCV and PBV programs until October 1, 2024.
Condition: Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff.
Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards.
Questioned costs: No known or estimated questioned costs identified.
Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard. Per the Federal Register announcement in May 2023, HUD extended the compliance date for HCV and PBV programs until October 1, 2024.
Condition: Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff.
Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards.
Questioned costs: No known or estimated questioned costs identified.
Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard. Per the Federal Register announcement in May 2023, HUD extended the compliance date for HCV and PBV programs until October 1, 2024.
Condition: Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff.
Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards.
Questioned costs: No known or estimated questioned costs identified.
Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.267 Continuum of Care Program
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.1., Reasonable Rental Rates, requires the County to conduct a reasonable rent analysis. Per 24 CFR 578.49(b)(1) and 24 CFR 578.51(g), when grant funds are used to pay for all or part of the rent for a structure, the rent must be reasonable in relation to rents charged for comparable space in the area.
Condition: Internal controls over compliance with requirement N.1 related to reasonable rental rates in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 313 rental units/tenants, 60 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for 3 units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.267 Continuum of Care Program
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement G.1., Matching, requires a match of no less than 25%.
Condition: Internal controls over compliance with requirement G.1. related to a match of no less than 25% in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff.
Effect: A lack of effective internal controls over the review of payroll and administrative expenditure matching was occurring and may result in unallowable costs being used to match.
Questioned costs: No known or estimated questioned costs identified.
Context: The match of no less than 25% was appropriately calculated for the fiscal year; however, evidence of a review of the calculations was not retained.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that payroll and administrative expenditure matching is reviewed to ensure the 25% matching requirement is met and costs used to match are allowable.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD 52681-B report is required to be submitted monthly in HUD’s most current automated system.
Condition: Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD.
Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD 52681-B report is required to be submitted monthly in HUD’s most current automated system.
Condition: Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD.
Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD 52681-B report is required to be submitted monthly in HUD’s most current automated system.
Condition: Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD.
Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement E., Eligibility, condition of admission or continued occupancy is required to obtain necessary information from tenant and (or) other family members and review the necessary information by program supervisor or program manager.
Condition: Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing.
Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement E., Eligibility, condition of admission or continued occupancy is required to obtain necessary information from tenant and (or) other family members and review the necessary information by program supervisor or program manager.
Condition: Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing.
Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement E., Eligibility, condition of admission or continued occupancy is required to obtain necessary information from tenant and (or) other family members and review the necessary information by program supervisor or program manager.
Condition: Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing.
Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.2., Reasonable Rent, requires the County to conduct a reasonable rent analysis when tenant is admitted to a new unit.
Condition: Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.2., Reasonable Rent, requires the County to conduct a reasonable rent analysis when tenant is admitted to a new unit.
Condition: Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.2., Reasonable Rent, requires the County to conduct a reasonable rent analysis when tenant is admitted to a new unit.
Condition: Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard. Per the Federal Register announcement in May 2023, HUD extended the compliance date for HCV and PBV programs until October 1, 2024.
Condition: Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff.
Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards.
Questioned costs: No known or estimated questioned costs identified.
Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard. Per the Federal Register announcement in May 2023, HUD extended the compliance date for HCV and PBV programs until October 1, 2024.
Condition: Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff.
Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards.
Questioned costs: No known or estimated questioned costs identified.
Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard. Per the Federal Register announcement in May 2023, HUD extended the compliance date for HCV and PBV programs until October 1, 2024.
Condition: Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff.
Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards.
Questioned costs: No known or estimated questioned costs identified.
Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.267 Continuum of Care Program
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.1., Reasonable Rental Rates, requires the County to conduct a reasonable rent analysis. Per 24 CFR 578.49(b)(1) and 24 CFR 578.51(g), when grant funds are used to pay for all or part of the rent for a structure, the rent must be reasonable in relation to rents charged for comparable space in the area.
Condition: Internal controls over compliance with requirement N.1 related to reasonable rental rates in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff.
Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance.
Questioned costs: No known or estimated questioned costs identified.
Context: Out of a population of 313 rental units/tenants, 60 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for 3 units/tenants.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained.
Views of responsible officials: The County understands and concurs with the finding.
Federal program: AL 14.267 Continuum of Care Program
Federal agency: U.S. Department of Housing and Urban Development (HUD)
Award year: 2024
Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement G.1., Matching, requires a match of no less than 25%.
Condition: Internal controls over compliance with requirement G.1. related to a match of no less than 25% in the 2024 OMB Compliance Supplement were not implemented and operating as designed.
Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff.
Effect: A lack of effective internal controls over the review of payroll and administrative expenditure matching was occurring and may result in unallowable costs being used to match.
Questioned costs: No known or estimated questioned costs identified.
Context: The match of no less than 25% was appropriately calculated for the fiscal year; however, evidence of a review of the calculations was not retained.
Repeat finding: No.
Recommendation: The County should develop and implement policies and procedures to ensure that payroll and administrative expenditure matching is reviewed to ensure the 25% matching requirement is met and costs used to match are allowable.
Views of responsible officials: The County understands and concurs with the finding.