Audit 41271

Assistance Listing Number, Federal Agency, and Program Name: 14.850, U.S. Department of Housing and Urban Development, Public and Indian Housing Federal Award Identification Number and Year: N/A Pass through Entity: N/A Finding Type: Material weakness Repeat Finding: No Criteria: As a condition of a tenant's admission or continued occupancy, the Commission is required to examine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using documentation from third party verification (24 CFR sections 960.253, 960.257, and 960.259) Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not perform reexaminations within the required 12 month timeline, did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Questioned Costs: N/A Identification of How Questioned Costs Were Computed: N/A Context: During testing of 40 tenants selected for eligibility testing, we identified the following issues: For 5 of the 40 tenants selected, the Commission did not perform eligibility reexaminations within 12 months of the previously performed examination. For 1 of the 40 tenants selected, the Commission was unable to provide original documentation from a tenant's file to support that tenant's consent was obtained or that related third party support was obtained in connection with determination of eligibility and calculation of assistance. For 1 of the 40 selections, the Commission did not retain documentation of the tenant's ID/Social Security number to independently verify citizenship For 4 of our 40 selections, the Commission incorrectly calculated the tenants' annual income due to administrative errors leading to inputs in to the calculation not agreeing to the underlying third party income verification received Cause and Effect: Controls to ensure eligibility recertifications were performed in accordance with federal regulations were not consistently followed. This led to an inability by the Commission to identify all timeliness and retention issues, as well as family income composition calculation errors. Recommendation: The Commission should ensure that they have the appropriate controls and personnel in place to perform all reexamintaions in accordance with federal regulations. This includes a proper review to ensure recertifications are completed within the required 12 month period, that family income composition is properly calculated, and that appropriate documentation is retained in the tenant's file to support the eligibility determinations made. Views of Responsible Officials and Corrective Action Plan: The commission is implementing a plan to audit internally 100% of all tenant files in our Low Income Public Housing (LIPH) program. This plan involves both the use of experienced employees and an outside consultant. The plan includes updating and automating files, identifying recurring compliance issues and expanding formal training and specific training from the consultant. In addition, an additional level of review will be put in place to assist in catching any inconsistencies. The Commission has added additional employees to the LIPH program which include an operations manager and a staff person. These additional resources will be incorporated into our overall plan to increase our compliance controls.

Assistance Listing Number, Federal Agency, and Program Name: 14.850, U.S. Department of Housing and Urban Development, Public and Indian Housing Federal Award Identification Number and Year: N/A Pass through Entity: N/A Finding Type: Material weakness Repeat Finding: No Criteria: As a condition of a tenant's admission or continued occupancy, the Commission is required to examine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using documentation from third party verification (24 CFR sections 960.253, 960.257, and 960.259) Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not perform reexaminations within the required 12 month timeline, did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Questioned Costs: N/A Identification of How Questioned Costs Were Computed: N/A Context: During testing of 40 tenants selected for eligibility testing, we identified the following issues: For 5 of the 40 tenants selected, the Commission did not perform eligibility reexaminations within 12 months of the previously performed examination. For 1 of the 40 tenants selected, the Commission was unable to provide original documentation from a tenant's file to support that tenant's consent was obtained or that related third party support was obtained in connection with determination of eligibility and calculation of assistance. For 1 of the 40 selections, the Commission did not retain documentation of the tenant's ID/Social Security number to independently verify citizenship For 4 of our 40 selections, the Commission incorrectly calculated the tenants' annual income due to administrative errors leading to inputs in to the calculation not agreeing to the underlying third party income verification received Cause and Effect: Controls to ensure eligibility recertifications were performed in accordance with federal regulations were not consistently followed. This led to an inability by the Commission to identify all timeliness and retention issues, as well as family income composition calculation errors. Recommendation: The Commission should ensure that they have the appropriate controls and personnel in place to perform all reexamintaions in accordance with federal regulations. This includes a proper review to ensure recertifications are completed within the required 12 month period, that family income composition is properly calculated, and that appropriate documentation is retained in the tenant's file to support the eligibility determinations made. Views of Responsible Officials and Corrective Action Plan: The commission is implementing a plan to audit internally 100% of all tenant files in our Low Income Public Housing (LIPH) program. This plan involves both the use of experienced employees and an outside consultant. The plan includes updating and automating files, identifying recurring compliance issues and expanding formal training and specific training from the consultant. In addition, an additional level of review will be put in place to assist in catching any inconsistencies. The Commission has added additional employees to the LIPH program which include an operations manager and a staff person. These additional resources will be incorporated into our overall plan to increase our compliance controls.