Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: WA001 - 2025 Award Period: January 1, 2025 through December 31, 2025 Compliance Requirement: Eligibility (LIPH) Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: According to Part 4 of the Compliance Supplement 2025 for the Moving to Work Demonstration Program, “Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))).” According to 24 CFR 960.257(d) PHA reexamination policies, “The PHA must adopt admission and continued occupancy policies concerning conduct of annual and interim reexaminations in accordance with this section, and shall conduct reexaminations in accordance with such policies.” According to the Authority’s Admissions and Continued Occupancy Policy (ACOP), “The method of calculating income and rent must be documented in the applicant or resident file. All verification attempts, information obtained, and decisions reached during the verification process must be recorded in the family’s file in sufficient detail to demonstrate that all of the verification policies required under the rules and regulations of the Public Housing program, or other housing program as may be relevant, have been followed.” According to the ACOP, “SHA must periodically certify that households are eligible for housing subsidy. To provide this certification, SHA must conduct an annual reexamination (at least once every 12 months) of family composition and income for non-elderly, non-disabled households and a triennial reexamination (at least once every 36 months) of households in which all adult family members are elderly and/or disabled.” Condition: During testing, we noted the Authority lacked adequate internal controls to ensure documentation was maintained in the tenant file and properly supported the Housing Assistance Payment (HAP) in accordance with federal regulation and Authority policy. Questioned costs: None Context: During testing, we identified the following eligibility issues in four separate files: • Three of forty sampled tenant files lacked documentation supporting income eligibility. • Two of forty sampled tenant files did not include evidence of an annual reexamination as of the effective date. • One of forty sampled tenant files did not accurately reflect annual income obtained from the Enterprise Income Verification (EIV) system. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative policy. Effect: The Authority may be providing housing assistance to families who are either not eligible for the program or receiving assistance in excess of what is allowed. Repeat Finding: No. Recommendation: We recommend the Authority design and implement controls to ensure tenant files include documentation supporting both initial and ongoing income eligibility, in accordance with federal regulation and Authority policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: WA001 - 2025 Award Period: January 1, 2025 through December 31, 2025 Compliance Requirement: Eligibility (HCV) Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: According to Part 4 of the Compliance Supplement 2025 for the Housing Voucher Cluster, “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 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD.” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “It is required that all adult applicants and participants sign a Release of Information form. The purpose of this form is to facilitate automated data collection and computer matching from specific sources and provides the family's consent only for the specific purposes listed on the form. HUD.” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “SHA will obtain income reports for annual reexaminations on a monthly basis. Reports will be generated as part of the regular reexamination process. EIV will also be used to verify that families claiming zero income are not receiving income from any of these sources. Income reports will be retained in participant files with the applicable annual or interim reexamination documents” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “SHA will check UIV sources and/or request information from third-party sources to verify that certain forms of income such as unemployment benefits, TANF, SS, SSI, and earnings are not being received by families claiming to have zero annual income. Applicants must submit an affidavit attesting to reported income, assets, expenses and other factors which would affect an income eligibility determination.” Condition: During testing, we noted the Authority lacked adequate internal controls to ensure documentation was maintained in the tenant file and properly supported the Housing Assistance Payment (HAP) in accordance with federal regulation and Authority policy. Questioned costs: $72,204 Context: During testing, we identified the following eligibility issues in four separate files: • Income reexamination: Two of forty sampled tenant files did not contain third-party verification (such as EIV) demonstrating reexamination of family income and composition at least once every 12 months. • Zero-income affidavit: One of forty sampled tenant files did not contain an affidavit attesting to zero income. • Release of Information: Three of forty sampled tenant files did not include signed Release of Information consent forms applicable to the eligible time frame. • Internal control checklist: Two of forty sampled tenant files did not show evidence that an internal control checklist was completed for the effective date. • Supporting documentation: One of forty sampled tenant files lacked supporting documentation for the effective date; the reexamination was not completed. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative policy. Effect: The Authority may be providing housing assistance to families who are either not eligible for the program or receiving assistance in excess of what is allowed. Repeat Finding: Yes. See prior year finding 2024-006. Recommendation: We recommend the Authority design and implement controls to ensure tenant files include documentation supporting both initial and ongoing eligibility, in accordance with federal regulation and Authority policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: WA001 - 2025 Award Period: January 1, 2025 through December 31, 2025 Compliance Requirement: Special Tests and Provisions - Housing Quality Standards Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: According to Part 4 of the Compliance Supplement 2025 for the Moving to Work Demonstration Program, “MTW Agencies must ensure that housing assisted under the demonstration program meets housing quality standards established or approved by the Secretary. The HCV program regulations at 24 CFR sections 982.401 through 982.405 set forth basic housing quality standards (HQS) which all units must meet, and the PHA must verify by inspection, before initial assistance can be paid on behalf of a family and at least annually throughout the term of the assisted tenancy. Current HQS regulations consist of 13 key aspects of housing quality, performance requirements, and acceptability criteria to meet each performance requirement. HQS include requirements for all housing types, including single and multi-family dwelling units, as well as specific requirements for special housing types, such as manufactured homes, congregate housing, single room occupancy, shared housing, and group residences (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))).” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “MTW Units: SHA conducts an inspection to determine continuing compliance with Housing Quality Standards within 26 months of the last inspection (MTW 3.A.01). SHA reserves the right to place units on an annual inspection or another alternative schedule if deemed appropriate. SHA will complete a full recertification on a triennial basis for families where all adults in the household are elderly or disabled (unless the entire household has no income).” Condition: During testing, we noted the Authority lacked adequate internal controls to ensure housing inspections were performed when due. Questioned costs: None Context: During testing, we identified the following HQS issue: one of the forty sampled tenant files did not contain evidence of a required triennial inspection. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative policy. Effect: The tenant may not be receiving housing that is safe, sanitary, or structurally sound. Repeat Finding: Yes. See prior year finding 2024-007. Recommendation: We recommend the Authority design and implement controls to ensure housing inspections are performed when due. Such controls should include assigning a responsible individual to manage the inspection schedule and to monitor and follow up on all inspection dates to prevent missed inspections. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871 and 14.879 Federal Award Identification Number and Year: WA001DV0079-83 - 2025 WA001EH014, WA001EH0013, 15-16 - 2025 Award Period: January 1, 2025 through December 31, 2025 Compliance Requirement: Eligibility Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: According to Part 4 of the Compliance Supplement 2025 for the Housing Voucher Cluster, “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) 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).” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “It is required that all adult applicants and participants sign a Release of Information form. The purpose of this form is to facilitate automated data collection and computer matching from specific sources and provides the family's consent only for the specific purposes listed on the form. HUD.” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “SHA will begin the annual reexamination process 120 days in advance of its scheduled effective date. Generally, SHA will schedule annual reexamination effective dates to coincide with the family’s anniversary date.” Condition: During testing, we noted the Authority lacked adequate internal controls to ensure documentation was maintained in the tenant file and properly supported the Housing Assistance Payment (HAP) in accordance with federal regulation and Authority policy. Questioned costs: $24,084 Context: During testing, we identified the following eligibility issues in three separate files: • One of forty sampled tenant files did not include a signed Release of Information consent form applicable to the eligible time frame. • Two of forty sampled tenant files did not have the annual reexamination completed. Cause: For reexaminations that were not completed, the Authority implemented an administrative reexamination process to address the backlog. This process relied on prior-year information, rather than conducting an actual reexamination, in order to move forward with current-year reexaminations. The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative policy. Effect: The Authority may be providing housing assistance to families who are either not eligible for the program or receiving assistance in excess of what is allowed. Repeat Finding: Yes. See prior year finding 2024-004. Recommendation: We recommend the Authority design and implement controls to ensure tenant files include documentation supporting both initial and ongoing eligibility, in accordance with federal regulation and Authority policy. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871 and 14.879 Federal Award Identification Number and Year: WA001DV0079-83 - 2025 Award Period: January 1, 2025 through December 31, 2025 Compliance Requirement: Special Tests and Provisions - HQS Enforcement (Failed Inspections) Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: According to Part 4 of the Compliance Supplement 2025 for the Housing Voucher Cluster, “For units under HAP contract that fail to meet HQS, if the reported deficiency is life-threatening, the PHA must, within 24 hours of notification, both inspect the housing unit and notify the owner if the life-threatening deficiency is confirmed. The owner must then make the repairs within 24 hours of PHA notification. If the reported deficiency is non-life-threatening, the PHA must, within 15 days of notification, both inspect the unit and notify the owner if the deficiency is confirmed. The owner must then make the repairs within 30 days of notification from the PHA or within any PHA-approved extension. (24 CFR section 982.405(d)). If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA 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 PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404).” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “The owner and the family will be notified in writing of the results of failed inspections. When an inspection identifies HQS failures, the PHA will determine (1) whether or not the failure is a life-threatening condition and (2) whether the family or owner is responsible. The notice of inspection results will inform the owner that if life-threatening conditions are not corrected within 24 hours, urgent conditions are not corrected within 72 hours and non-life-threatening conditions are not corrected within the specified time frame the owner’s HAP will be abated in accordance with PHA policy. Likewise, in the case of family caused deficiencies the notice will inform the family that if corrections are not made within the specified time frame the family’s assistance will be terminated in accordance with PHA policy.” Condition: During testing, we noted the Authority lacked adequate internal controls to ensure failed inspections were completed in accordance with compliance requirements. Questioned costs: $4,652 Context: During testing, we identified the following inspection issues in two separate files: • One of the sixty sampled tenant files included two inspection entries dated the same day—one indicating a pass and the other indicating a fail with referral to abatement. Consequently, the final inspection status for this unit cannot be determined. • One of the sixty sampled tenant files lacked evidence of a completed reinspection. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative policy. Effect: The tenant may not be receiving housing that is safe, sanitary, or structurally sound. Repeat Finding: Yes. See prior year finding 2024-002. Recommendation: We recommend the Authority design and implement controls to ensure enforcement of HQS. These controls should include assigning a responsible individual to manage the reinspection schedule and to monitor and follow up on all reinspection dates, preventing inconsistent and missed reinspection. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871 and 14.879 Federal Award Identification Number and Year: WA001EH014, WA001EH0013, 15-16 - 2025 WA001VO0535, 549, 552, 554-7, WA001546-8 - 2025 Award Period: January 1, 2025 through December 31, 2025 Compliance Requirement: Special Tests and Provisions - NSPIRE / Housing Quality Standards Inspections Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: According to Part 4 of the Compliance Supplement 2025 for the Housing Voucher Cluster, “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)). However, NSPIRE for HCV and Project Based Vouchers (PBV) programs, referred to as NSPIRE-V during HUD’s demonstration, was effective October 1, 2023, and replaced HQS, as previously defined in 24 CFR 982.401, as the inspection standards for these programs. As announced in the Federal Register, “Economic Growth Regulatory Relief and Consumer Protection Act: Implementation of National Standards for the Physical Inspection of Real Estate (NSPIRE); Extension of NSPIRE Compliance Date for HCV Programs,” HUD extended the compliance date for HCV and PBV programs until October 1, 2024. This applies to all Public Housing Agencies (PHAs), including MTW PHAs, administering Section 8 Housing Choice Voucher programs.” According to the Authority’s Housing Choice Voucher Program Administrative Plan updated August 25th, 2025, “All units must pass an NSPIRE inspection prior to the approval of a lease (with some exceptions) and at least once every 26 months during the term of the HAP contract, and at other times as needed, to determine that the unit meets NSPIRE.” Condition: During testing, we noted the Authority lacked adequate internal controls to ensure NSPIRE inspections were completed in accordance with compliance requirements. Questioned costs: None Context: During testing, we identified an NSIPE inspections issue: three of the forty sampled inspections were not conducted on a biennial or triennial basis. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative policy. Effect: The tenant may not be receiving housing that is safe, sanitary, or structurally sound. Repeat Finding: Yes. See prior year finding 2024-005. Recommendation: We recommend the Authority design and implement controls to ensure NSPIRE inspections are conducted on schedule. These controls should include assigning a responsible individual to manage the inspection schedule, as well as monitoring and following up on all inspection dates to prevent delayed or missed inspections. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871 and 14.879 Federal Award Identification Number and Year: WA001EH014, WA001EH0013, 15-16 - 2025 Award Period: January 1, 2025 through December 31, 2025 Compliance Requirement: Special Tests and Provisions - Housing Assistance Payment Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: According to Part 4 of the Compliance Supplement 2025 for the Housing Voucher Cluster, “The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Verify a HAP contract and tenancy addendum has been fully executed. A "fully executed HAP" for the HCV Program means that the Housing Assistance Payments contract between the landlord (owner) and the Public Housing Agency (PHA) has been signed by both parties, signifying that the landlord has agreed to lease a unit to a voucher holder and the PHA has approved the unit and will provide housing assistance payments to the landlord on behalf of the tenant, with all necessary documents and conditions met according to HUD regulations. Similarly, a "tenancy addendum" is considered fully executed when both the landlord and tenant have signed the document, signifying their agreement to the additional terms and conditions outlined within it, which are now legally binding and part of the overall lease agreement; essentially, all parties involved have completed their required actions by signing the addendum.” Condition: During testing, we noted the Authority lacked adequate internal controls to ensure that a fully executed HAP contract and tenancy addendum were included in tenant files. Questioned costs: None Context: During testing, we identified the following HAP issues in four separate files: • Three of the forty sampled tenant files did not include a fully executed HAP contract signed by both the landlord (owner) and the PHA. • Four of the forty sampled tenant files did not include a fully executed tenancy addendum signed by both the landlord and the tenant. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations. Effect: The Authority lacks documentation to support the tenancy. Repeat Finding: No. Recommendation: We recommend the Authority design and implement controls to ensure tenant files include a fully executed HAP contract and tenancy addendum, including a review of the tenant file before the family moves in. Views of responsible officials: There is no disagreement with the audit finding.