Housing Voucher Cluster – HQS QC Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2023-2024 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2023 – December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Per the Authority's administrative plan, the re-inspection must be performed within 3 months (90 days) of the original inspection. Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure compliance over HQS quality control re-inspection requirements was met. Context: During our testing of 6 files for quality control re-inspections, we noted that 6 of the files contained re-inspections that were not performed within 3 months of the original inspection. 1 file did not list the QC inspector's name. 1 file had the same inspector for both the original and quality control reinspection. Additionally, we noted only 19 quality control re-inspections were performed for the 18 month period. Questioned costs: Unable to determine Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Additional training will be provided to staff. Effect: The Authority is not in compliance with HUD regulations. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the Authority review their quality control re-inspection process to ensure the inspections are performed timely and in accordance with the SEMAP requirements. We recommend that the Authority utilize Yardi software to its full potential in terms of inspection documentation. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002 – Housing Voucher Cluster – HQS Enforcement - Failed Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2023-2024 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2023 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the PHA 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 PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAP's beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure compliance over HQS enforcement requirements was met. Context: During our testing of 15 failed HQS inspections, we noted 1 instance where HAP was not abated and the tenant did not change units. There was no documentation that the unit ever passed inspection. Additionally, we noted there only 94 failed inspections per the population received. Questioned costs: $5,915 Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Effect: The Authority is not in compliance with HUD regulations. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the Authority review their failed inspection process to ensure that any abatement/contract modifications are performed timely and in accordance with the compliance requirements. We recommend that the Authority utilize Yardi software to its full potential in terms of inspection documentation. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster - Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2023-2024 Award Period: July 1, 2023 – December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must do the following: (1) 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). (2) 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). (3) 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). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Reexamine family income and composition at least once every 12months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24CFR section 982.516). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure compliance over eligibility requirements was met. Context: During our testing of 60 tenants for eligibility requirements, we noted the following: - 6 of 60 tenant files tested did not have a signed Declaration 214 for all members of the household - 12 of 60 tenant files tested did not have proper support for income - 12 of 60 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses - 9 of 60 tenant files tested did not have a signed HUD-9886 in place Questioned costs: $45,998. Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations over eligibility. This could have an impact on HAP calculations. Repeat Finding: Yes, 2023-003. Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and documented. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster - HQS Biennial Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2023-2024 Award Period: July 1, 2023 – December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA 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: During our testing, we noted the Authority did not have adequate internal controls designed to ensure compliance over HQS inspections requirements was met. Context: During our testing of 60 units for biennial HQS requirements, we noted the following: - 18 of 60 units tested did not have documentation of a completed HQS inspection within 24 months of the effective date. - 36 of 60 units tested did not have inspections performed on a biennial basis. - 1 of 60 inspections tested did not have an inspection report that was signed off as completed by the inspector. Questioned costs: Unable to determine Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Effect: The Authority is not in compliance with HUD regulations regarding HQS inspections. Repeat Finding: Yes, 2023-004. Recommendation: We recommend the Authority review their inspection process to ensure that inspections are performed timely and that all documentation is maintained within Yardi or the tenant file. We recommend the Authority hiring additional inspectors or a third-party company to perform inspections to ensure compliance. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster - Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2023-2024 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2023 – December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must determine that the rent to the 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 5% decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure compliance over reasonable rent requirements was met. Context: During our testing of 120 files for rent reasonableness requirements, we noted the following: - 60 out of 120 files did not have a tenant-signed lease amendment that tied to the approved rental request form. - 53 of 120 files tested did not have a rent reasonableness determination form completed before the rent effective date. - 44 of 120 files tested did not have a rent reasonableness determination form completed. Questioned costs: None Cause: The Authority has had turnover in the staff who perform the rent reasonableness determinations, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD’s requirements over rent reasonableness. This could have an impact on HAP calculations. Repeat Finding: Yes, 2023-005. 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.
Housing Voucher Cluster – Waitlist – New Tenants Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2023-2024 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2023 – December 31, 2024 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: During our testing, we noted the Authority did not have adequate internal controls designed to ensure compliance over waitlist – new tenant requirements was met. Context: During our testing of 24 files for new tenants selected off of the waitlist, the Authority was unable to locate 1 file. Questioned costs: None Cause: The Authority has had vacancies and turnover in the staff who perform these processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations. Repeat Finding: No. 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.