Audit 367447

Finding 2024-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021 (2021-001), 2022 (2022-001), and 2023 (2023-001) Condition: During our review of 40 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted four instances where a tenant recertification using the Form HUD-50058, Family Report (Form) (which provides eligibility and reporting information) was not completed on a timely basis. We also noted one instance where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 was not provided. This includes items such as support for income calculation and medical deductions. These exceptions indicate a lack of functioning internal controls and oversight to ensure compliance with HUD requirements related to timely and accurate tenant recertifications. Criteria: The Authority is required to prepare and submit the Form each time the Authority completes an admission, bi-annual reexamination, portability move-in, or other change of unit for a family. The form provides HUD and the Authority with vital eligibility data for each program participant such as family composition, family income, the assets and liabilities of program participants, and ultimately provides for the calculation of tenant rent and rental/housing assistance payments for each program participant. In relation to the missing documents noted above, these documents are to be maintained to support the eligibility of the tenant, and are also required to be maintained to provide support for the tenant income and eligibility determinations completed on the Form. Cause: There was a lack of functioning internal control over the recertification process that were exacerbated by turnover and logistical staffing challenges in recent years. Effect: The Form provides essential information to HUD as well as being used by the Authority to determine program eligibility. In addition, the Form is used for the calculation of tenant rent and rental/housing assistance payments. Without this required documentation, this could lead to ineligible tenants being housed through the Authority program, and/or overpayments or underpayments of rental assistance, and incorrect information being reported to HUD. Questioned Costs: Unknown Recommendation: We recommend that the Authority implement additional procedures to ensure biennial recertification and the related Forms are prepared timely and accurately and that all supporting documentation is obtained and retained. In addition, appropriate training and planning should be performed to ensure that future turnover in the organization does not lead to a lapse in internal controls over compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.