Finding No. 2022-003 Program: Section 8 Project Based Cluster Assistance Listing No.: 14.182, 14.195, 14.249 & 14.856 Federal Agency: Department of Housing and Urban Development Award No.: RQ006SC0001, RQ006MR0001, RQ006MR0003 & RQ006MR0004 Federal Award Year: 2022 Compliance Requirement: Eligibility - Notice of Re-certification sent within 90 to 120 days. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non- Compliance Criteria: Annual Re-certification [24 CFR sections 5.617, 880.603, 881.601, 882.515, 884.218, 886.124 y 886.324] Municipality of San Juan Housing Department Housing Authority of the Municipality of San Juan will maintain an automated re-certification tracking system and households will be notified by mail of the date and time for scheduled appointments a minimum of 90 days in advance of the anniversary date of their lease and Housing Assistance Payments contract. A listing of all required documentation necessary for the annual re-certification will be provided to the family with the notification of scheduled appointment. This information includes all documentation necessary to verify income, assets, allowances, and deductions along with any additions or deletions of household members. Condition: The Notice of Re-certification wasn?t observed in 1 case of a selected sample of 40 cases. Cause: This situation occurred because the Housing Department did not follow the required procedure as per the Code of Federal Regulations to notify the participants. Due to the backlog in the cases caused by the Covid-19 pandemic, they communicated directly by phone with the participants. Effect: If the family does not appear for the recertification interview, the caseworker may issue a notice of termination of assistance. Questioned Costs None Recommendation: The Housing Department should maintain and adopt a quality control review and checklist that includes all related documents and processes that must be completed for each participant. These procedures will help improve controls and documentation of participant eligibility and reduce the chance of noncompliance. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan
Finding No. 2022-001 Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Special Test - Housing Quality Standards Inspections-HQS Enforcement Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: The PHA must inspect the unit leased to a family at least annually 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)). Compliance Requirements 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) 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). Condition: We were unable to observe the updated Housing Quality Standards (HQS) in 2 cases out of a selected sample of 40 cases. Cause: These situations occur because the internal control system of the Housing Authority of the Municipality of San Juan related to the requirements of Housing Quality Standards Inspections is not effectively identifying the regularity of the inspections. We were able to observe the Housing Quality Standards Inspections update for the following year. Effect: This situation has the effect of not meeting the Basic Housing Quality Standards (HQS) (24 CFR Part 982), which all units must meet before assistance can be paid on behalf of a family and at least annually during the term of the assisted lease. HQS defines "standard housing" and sets minimum criteria for the health and safety of program participants. Questioned Costs None Recommendation: Improves the planning of Housing Quality Standards Inspections to meet the due dates. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan
Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Eligibility - Form HUD-92006, Supplement to Application for Federally Assisted Housing. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: Applicants must be provided the opportunity to complete the information on form HUD-92006, Supplement to Application for Federally Assisted Housing. The form gives applicants the option to identify an individual or organization that the O/A or PHA may contact and the reason(s) the individual or organization may be contacted. The applicants, if they choose to provide the additional contact information, must sign and date the form. Condition: We were able to observe 12 cases out of 40 cases in the selected sample where the HUD Form-92006, Supplement to Federally Assisted Housing Application could not be located. Cause: These situations occur because internal controls regarding the handling of documentation in the eligibility process are not effective as required by HUD compliance. We were able to observe for the subsequent year the use of this HUD-92006 form. Effect: Failure to provide information that facilitates the housing provider's contact with the person or organization identified by the tenant and that helps provide any special services or attention to the tenant and that may help resolve any tenancy issues that arise during the possession of said lessee. Questioned Costs None Recommendation: Improve documentation management processes when evaluating participants. Review and train program staff regarding necessary and HUD required documents. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan
Finding No. 2022-003 Program: Section 8 Project Based Cluster Assistance Listing No.: 14.182, 14.195, 14.249 & 14.856 Federal Agency: Department of Housing and Urban Development Award No.: RQ006SC0001, RQ006MR0001, RQ006MR0003 & RQ006MR0004 Federal Award Year: 2022 Compliance Requirement: Eligibility - Notice of Re-certification sent within 90 to 120 days. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non- Compliance Criteria: Annual Re-certification [24 CFR sections 5.617, 880.603, 881.601, 882.515, 884.218, 886.124 y 886.324] Municipality of San Juan Housing Department Housing Authority of the Municipality of San Juan will maintain an automated re-certification tracking system and households will be notified by mail of the date and time for scheduled appointments a minimum of 90 days in advance of the anniversary date of their lease and Housing Assistance Payments contract. A listing of all required documentation necessary for the annual re-certification will be provided to the family with the notification of scheduled appointment. This information includes all documentation necessary to verify income, assets, allowances, and deductions along with any additions or deletions of household members. Condition: The Notice of Re-certification wasn?t observed in 1 case of a selected sample of 40 cases. Cause: This situation occurred because the Housing Department did not follow the required procedure as per the Code of Federal Regulations to notify the participants. Due to the backlog in the cases caused by the Covid-19 pandemic, they communicated directly by phone with the participants. Effect: If the family does not appear for the recertification interview, the caseworker may issue a notice of termination of assistance. Questioned Costs None Recommendation: The Housing Department should maintain and adopt a quality control review and checklist that includes all related documents and processes that must be completed for each participant. These procedures will help improve controls and documentation of participant eligibility and reduce the chance of noncompliance. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan
Finding No. 2022-001 Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Special Test - Housing Quality Standards Inspections-HQS Enforcement Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: The PHA must inspect the unit leased to a family at least annually 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)). Compliance Requirements 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) 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). Condition: We were unable to observe the updated Housing Quality Standards (HQS) in 2 cases out of a selected sample of 40 cases. Cause: These situations occur because the internal control system of the Housing Authority of the Municipality of San Juan related to the requirements of Housing Quality Standards Inspections is not effectively identifying the regularity of the inspections. We were able to observe the Housing Quality Standards Inspections update for the following year. Effect: This situation has the effect of not meeting the Basic Housing Quality Standards (HQS) (24 CFR Part 982), which all units must meet before assistance can be paid on behalf of a family and at least annually during the term of the assisted lease. HQS defines "standard housing" and sets minimum criteria for the health and safety of program participants. Questioned Costs None Recommendation: Improves the planning of Housing Quality Standards Inspections to meet the due dates. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan
Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Eligibility - Form HUD-92006, Supplement to Application for Federally Assisted Housing. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: Applicants must be provided the opportunity to complete the information on form HUD-92006, Supplement to Application for Federally Assisted Housing. The form gives applicants the option to identify an individual or organization that the O/A or PHA may contact and the reason(s) the individual or organization may be contacted. The applicants, if they choose to provide the additional contact information, must sign and date the form. Condition: We were able to observe 12 cases out of 40 cases in the selected sample where the HUD Form-92006, Supplement to Federally Assisted Housing Application could not be located. Cause: These situations occur because internal controls regarding the handling of documentation in the eligibility process are not effective as required by HUD compliance. We were able to observe for the subsequent year the use of this HUD-92006 form. Effect: Failure to provide information that facilitates the housing provider's contact with the person or organization identified by the tenant and that helps provide any special services or attention to the tenant and that may help resolve any tenancy issues that arise during the possession of said lessee. Questioned Costs None Recommendation: Improve documentation management processes when evaluating participants. Review and train program staff regarding necessary and HUD required documents. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan