Audit 360138

Finding 2024-001 – HUD Comprehensive Compliance Monitoring Review, Public Housing Program –14.850, Housing Choice Vouchers – 14.871, Resident Opportunities and Supportive Services -14.870 Family Self-Sufficiency Program – 14.896; Grant Period – year ended September 30, 2024. Criteria: The Code of Federal Regulations, the Public Housing Program Guidebook, the Housing Choice Voucher Program Guidebook and other HUD PIH Notices and Handbooks provide requirements and guidance for which the Housing Authority Programs are to be administered and operated under. Condition and Perspective: In June of 2024, HUD conducted a Comprehensive Compliance Monitoring Review of the Housing Authority’s Programs. The results of the Review included the following Findings: Finding #1 – The Authority is not providing a copy of the criminal record to the applicant prior to denying admission based on their criminal record. Finding #2 – The requirement to disclose all states in which the applicant has lived could not be found in the ACOP or Admin plan. The application does not include the requirement. Finding #3 – The Authority has not adopted new flat rents in over a year. While the Authority calculated flat rent amounts and circulated a notice to residents of new flat rents to be effective January 1, 2024, the Board did not adopt the new rents. Finding #4 – The Authority does not properly maintain its waiting list. The Authority lets applicants who refuse units remain on the waiting list. Per ACHA policy, applicants must be removed from the waiting list if they do not accept a unit upon offer and cannot show good cause for refusal. Finding #5 - Public Housing staff were not familiar with Individual Relief of utility allowances. Finding #6 – The Authority is not issuing residents notice or offering them the opportunity for a grievance hearing when assessing excess utility consumption costs. Finding #7 – The Authority is not enforcing its rent payment policies. Finding #8 - The Authority’s procedure for processing termination could not be followed in the resident files. Finding #9 – The Authority did not use the correct utility allowance to calculate rent and also there were errors in the rent calculations. Finding #10 – The Authority is using the actual unit size for the utility allowance as opposed to voucher size when the unit is larger. Finding #11 - The Authority does not notify the residents when HCV assistance is terminated. The Owner is notified but the family is not. Finding #12 - PHA is not allowing residents the opportunity to enter into repayment agreements for underreported/failure to report income for both HCV and Public Housing Program. Although the PHA has a Write-Off Policy and rent collection procedures in accordance with the Authority January 2024 ACOP, the PHA has a high TAR and written off allowance for doubtful accounts. Finding #13 - Quality Assurance Inspections are not being conducted. Finding #14 - The contractor log is not being maintained and updated with current procurement actions. Finding #15 - On the Top Gun Pest Control contract procurement package, there was not an Independent Cost Estimate provided at the time of the review. Finding #16 - On RFP number 230629 for Roof Eave Upgrade, the submittal deadline was November 30, 2023. At the time of the submittal deadline, only one proposal from AAA General Contractors, Inc., was received. A proposal from GutterPro LLC was submitted on January 19, 2024. Another proposal from Supreme Clean LLC was submitted on January 18, 2024. Finding #17 - The Authority has not completed a Physical Needs Assessment. Finding #18 - The Authority is not in compliance with the new Section 3 regulation of 24 CFR 75. Finding #19 – The Authority does not have any recent records of Section 3 businesses, workers or contractors that have been used or targeted. Finding #20 – The Authority has not ensured that subcontractors that employ workers maintain documentation that workers meet the definition of a Section 3 worker. Finding #21 – The Authority does not give all participants the notice of occupancy rights and certification form when denying assistance or admission, providing assistance or admission, or in cases of eviction or termination of assistance, as noticed in the file reviews. Finding #22 - In accordance with the FSS program the PHA is required at least on an annual basis to provide participants with proper notification of the participant’s escrow account balance. Finding #23 – The Authority cannot locate approvals for $1,039.87 withdrawn from the Training Costs line item in LOCCS in the ROSS Program.

Finding 2024-001 – HUD Comprehensive Compliance Monitoring Review, Public Housing Program –14.850, Housing Choice Vouchers – 14.871, Resident Opportunities and Supportive Services -14.870 Family Self-Sufficiency Program – 14.896; Grant Period – year ended September 30, 2024. Criteria: The Code of Federal Regulations, the Public Housing Program Guidebook, the Housing Choice Voucher Program Guidebook and other HUD PIH Notices and Handbooks provide requirements and guidance for which the Housing Authority Programs are to be administered and operated under. Condition and Perspective: In June of 2024, HUD conducted a Comprehensive Compliance Monitoring Review of the Housing Authority’s Programs. The results of the Review included the following Findings: Finding #1 – The Authority is not providing a copy of the criminal record to the applicant prior to denying admission based on their criminal record. Finding #2 – The requirement to disclose all states in which the applicant has lived could not be found in the ACOP or Admin plan. The application does not include the requirement. Finding #3 – The Authority has not adopted new flat rents in over a year. While the Authority calculated flat rent amounts and circulated a notice to residents of new flat rents to be effective January 1, 2024, the Board did not adopt the new rents. Finding #4 – The Authority does not properly maintain its waiting list. The Authority lets applicants who refuse units remain on the waiting list. Per ACHA policy, applicants must be removed from the waiting list if they do not accept a unit upon offer and cannot show good cause for refusal. Finding #5 - Public Housing staff were not familiar with Individual Relief of utility allowances. Finding #6 – The Authority is not issuing residents notice or offering them the opportunity for a grievance hearing when assessing excess utility consumption costs. Finding #7 – The Authority is not enforcing its rent payment policies. Finding #8 - The Authority’s procedure for processing termination could not be followed in the resident files. Finding #9 – The Authority did not use the correct utility allowance to calculate rent and also there were errors in the rent calculations. Finding #10 – The Authority is using the actual unit size for the utility allowance as opposed to voucher size when the unit is larger. Finding #11 - The Authority does not notify the residents when HCV assistance is terminated. The Owner is notified but the family is not. Finding #12 - PHA is not allowing residents the opportunity to enter into repayment agreements for underreported/failure to report income for both HCV and Public Housing Program. Although the PHA has a Write-Off Policy and rent collection procedures in accordance with the Authority January 2024 ACOP, the PHA has a high TAR and written off allowance for doubtful accounts. Finding #13 - Quality Assurance Inspections are not being conducted. Finding #14 - The contractor log is not being maintained and updated with current procurement actions. Finding #15 - On the Top Gun Pest Control contract procurement package, there was not an Independent Cost Estimate provided at the time of the review. Finding #16 - On RFP number 230629 for Roof Eave Upgrade, the submittal deadline was November 30, 2023. At the time of the submittal deadline, only one proposal from AAA General Contractors, Inc., was received. A proposal from GutterPro LLC was submitted on January 19, 2024. Another proposal from Supreme Clean LLC was submitted on January 18, 2024. Finding #17 - The Authority has not completed a Physical Needs Assessment. Finding #18 - The Authority is not in compliance with the new Section 3 regulation of 24 CFR 75. Finding #19 – The Authority does not have any recent records of Section 3 businesses, workers or contractors that have been used or targeted. Finding #20 – The Authority has not ensured that subcontractors that employ workers maintain documentation that workers meet the definition of a Section 3 worker. Finding #21 – The Authority does not give all participants the notice of occupancy rights and certification form when denying assistance or admission, providing assistance or admission, or in cases of eviction or termination of assistance, as noticed in the file reviews. Finding #22 - In accordance with the FSS program the PHA is required at least on an annual basis to provide participants with proper notification of the participant’s escrow account balance. Finding #23 – The Authority cannot locate approvals for $1,039.87 withdrawn from the Training Costs line item in LOCCS in the ROSS Program.