Audit 49580

FY End
2022-12-31
Total Expended
$25.01M
Findings
16
Programs
6
Year: 2022 Accepted: 2023-09-21

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
51966 2022-001 Significant Deficiency - L
51967 2022-002 Material Weakness - N
51968 2022-003 Material Weakness - N
51969 2022-004 Significant Deficiency - N
51970 2022-001 Significant Deficiency - L
51971 2022-002 Material Weakness - N
51972 2022-003 Material Weakness - N
51973 2022-004 Significant Deficiency - N
628408 2022-001 Significant Deficiency - L
628409 2022-002 Material Weakness - N
628410 2022-003 Material Weakness - N
628411 2022-004 Significant Deficiency - N
628412 2022-001 Significant Deficiency - L
628413 2022-002 Material Weakness - N
628414 2022-003 Material Weakness - N
628415 2022-004 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
14.871 Section 8 Housing Choice Vouchers $22.73M Yes 4
14.879 Mainstream Vouchers $1.19M Yes 4
21.023 Covid-19 - Emergency Rental Assistance Program $450,587 - 0
14.218 Community Development Block Grants/entitlement Grants $326,222 - 0
14.241 Housing Opportunities for Persons with Aids $250,315 - 0
14.896 Family Self-Sufficiency Program $67,165 - 0

Contacts

Name Title Type
SELJBFMGRED3 Peter Engel Auditee
4435187800 Gaby Miller Auditor
No contacts on file

Notes to SEFA

Title: NONCASH FEDERAL ASSISTANCE Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes thefederal award activity of the Howard County Housing Commission (the Commission) underprograms of the federal government for the year ended December 31, 2022. The informationin this Schedule is presented in accordance with the requirements of 2 CFR Part 200,Uniform Administrative Requirements, Cost Principles, and Audit Requirements for FederalAwards (Uniform Guidance). Because the Schedule presents only a selected portion of theoperations of the Commission, it is not intended to and does not present the financialposition, changes in net position, or cash flows of the Commission. Expenditures reported on the Schedule are reported on the accrual basis of accounting.Such expenditures are recognized following the principles contained in the UniformGuidance, wherein certain types of expenditures are not allowable or are limited as toreimbursement. Negative amounts shown on the Schedule represent adjustments or creditsmade in the normal course of business to amounts reported as expenditures in prior years.Pass-through, entity identifying numbers are presented where available. The Commissionhas elected to not use the 10 percent de minimis indirect cost rate as allowed under theUniform Guidance. De Minimis Rate Used: N Rate Explanation: The Commission has elected to not use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. The Commission did not receive any noncash federal assistance for the year ended December 31, 2022.

Finding Details

2022-001 ? PIC Uploads Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 24 CFR Part 908 and 24 CFR section 982.158 states that the PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA?s jurisdiction under portability. Condition: We noted that the Commission did not perform uploads of accurate information into the PIC system. Questioned costs: Unable to determine. Context: Testing of 40 HCVP tenants in PIC identified an exception in 7 files. In these instances, the tenant HUD 50058 forms were not uploaded to PIC. Cause: The commission did not return to their information they uploaded when the errors appeared and left them without being properly uploaded. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that management review their procedures for uploads to PIC to confirm the information is uploaded without error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-002 ? Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: The PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Per the Commission's administrative plan, before approving a rent increase, the HCHC must determine and document whether the proposed rent is reasonable compared to similar units in the marketplace and not higher than those paid by unassisted tenants. Condition: We noted that the Commission did not maintain consistent documentation regarding reasonable rent determination. Questioned costs: Unable to determine. Context: During our testing of 25 files for rent reasonableness, we noted the following: 7 out of 25 rent changes tested were missing a rent reasonableness form. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-003 ? HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 24 CFR sections 982.405(b) state that 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. Condition: The Commission did not follow its policies and procedures designed to ensure HQS inspections were performed timely. Questioned costs: Unable to determine. Context: During our testing of 40 files over HQS inspections, we noted the following: 21 of 40 units tested had an inspection that was not performed on a biennial basis as determined in the Administrative Plan. Cause: The Commission did not work closely with the inspection company with poorly written procedures in place for documenting inspections. The Commission experienced challenges during COVID in completing inspections timely. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-004 ? HQS Failed Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 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) HAPs beginning no later than the first of the month following the specified incorrect period or must terminate the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition: We noted that the Commission did not properly abate HAP for landlords in which units failed inspections. Questioned costs: $69,944 Context: During our testing of 40 files for HQS enforcement, we noted the following: 10 of 40 units tested failed inspection due to owner responsibilities and the Commission never abated HAP. 5 of 40 units tested failed due to tenant responsibilities and the Commission did not take proper steps to enforce family obligations. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan or as required by HUD. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-001 ? PIC Uploads Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 24 CFR Part 908 and 24 CFR section 982.158 states that the PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA?s jurisdiction under portability. Condition: We noted that the Commission did not perform uploads of accurate information into the PIC system. Questioned costs: Unable to determine. Context: Testing of 40 HCVP tenants in PIC identified an exception in 7 files. In these instances, the tenant HUD 50058 forms were not uploaded to PIC. Cause: The commission did not return to their information they uploaded when the errors appeared and left them without being properly uploaded. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that management review their procedures for uploads to PIC to confirm the information is uploaded without error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-002 ? Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: The PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Per the Commission's administrative plan, before approving a rent increase, the HCHC must determine and document whether the proposed rent is reasonable compared to similar units in the marketplace and not higher than those paid by unassisted tenants. Condition: We noted that the Commission did not maintain consistent documentation regarding reasonable rent determination. Questioned costs: Unable to determine. Context: During our testing of 25 files for rent reasonableness, we noted the following: 7 out of 25 rent changes tested were missing a rent reasonableness form. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-003 ? HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 24 CFR sections 982.405(b) state that 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. Condition: The Commission did not follow its policies and procedures designed to ensure HQS inspections were performed timely. Questioned costs: Unable to determine. Context: During our testing of 40 files over HQS inspections, we noted the following: 21 of 40 units tested had an inspection that was not performed on a biennial basis as determined in the Administrative Plan. Cause: The Commission did not work closely with the inspection company with poorly written procedures in place for documenting inspections. The Commission experienced challenges during COVID in completing inspections timely. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-004 ? HQS Failed Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 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) HAPs beginning no later than the first of the month following the specified incorrect period or must terminate the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition: We noted that the Commission did not properly abate HAP for landlords in which units failed inspections. Questioned costs: $69,944 Context: During our testing of 40 files for HQS enforcement, we noted the following: 10 of 40 units tested failed inspection due to owner responsibilities and the Commission never abated HAP. 5 of 40 units tested failed due to tenant responsibilities and the Commission did not take proper steps to enforce family obligations. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan or as required by HUD. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-001 ? PIC Uploads Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 24 CFR Part 908 and 24 CFR section 982.158 states that the PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA?s jurisdiction under portability. Condition: We noted that the Commission did not perform uploads of accurate information into the PIC system. Questioned costs: Unable to determine. Context: Testing of 40 HCVP tenants in PIC identified an exception in 7 files. In these instances, the tenant HUD 50058 forms were not uploaded to PIC. Cause: The commission did not return to their information they uploaded when the errors appeared and left them without being properly uploaded. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that management review their procedures for uploads to PIC to confirm the information is uploaded without error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-002 ? Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: The PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Per the Commission's administrative plan, before approving a rent increase, the HCHC must determine and document whether the proposed rent is reasonable compared to similar units in the marketplace and not higher than those paid by unassisted tenants. Condition: We noted that the Commission did not maintain consistent documentation regarding reasonable rent determination. Questioned costs: Unable to determine. Context: During our testing of 25 files for rent reasonableness, we noted the following: 7 out of 25 rent changes tested were missing a rent reasonableness form. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-003 ? HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 24 CFR sections 982.405(b) state that 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. Condition: The Commission did not follow its policies and procedures designed to ensure HQS inspections were performed timely. Questioned costs: Unable to determine. Context: During our testing of 40 files over HQS inspections, we noted the following: 21 of 40 units tested had an inspection that was not performed on a biennial basis as determined in the Administrative Plan. Cause: The Commission did not work closely with the inspection company with poorly written procedures in place for documenting inspections. The Commission experienced challenges during COVID in completing inspections timely. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-004 ? HQS Failed Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 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) HAPs beginning no later than the first of the month following the specified incorrect period or must terminate the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition: We noted that the Commission did not properly abate HAP for landlords in which units failed inspections. Questioned costs: $69,944 Context: During our testing of 40 files for HQS enforcement, we noted the following: 10 of 40 units tested failed inspection due to owner responsibilities and the Commission never abated HAP. 5 of 40 units tested failed due to tenant responsibilities and the Commission did not take proper steps to enforce family obligations. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan or as required by HUD. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-001 ? PIC Uploads Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 24 CFR Part 908 and 24 CFR section 982.158 states that the PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA?s jurisdiction under portability. Condition: We noted that the Commission did not perform uploads of accurate information into the PIC system. Questioned costs: Unable to determine. Context: Testing of 40 HCVP tenants in PIC identified an exception in 7 files. In these instances, the tenant HUD 50058 forms were not uploaded to PIC. Cause: The commission did not return to their information they uploaded when the errors appeared and left them without being properly uploaded. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that management review their procedures for uploads to PIC to confirm the information is uploaded without error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-002 ? Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: The PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Per the Commission's administrative plan, before approving a rent increase, the HCHC must determine and document whether the proposed rent is reasonable compared to similar units in the marketplace and not higher than those paid by unassisted tenants. Condition: We noted that the Commission did not maintain consistent documentation regarding reasonable rent determination. Questioned costs: Unable to determine. Context: During our testing of 25 files for rent reasonableness, we noted the following: 7 out of 25 rent changes tested were missing a rent reasonableness form. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-003 ? HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 24 CFR sections 982.405(b) state that 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. Condition: The Commission did not follow its policies and procedures designed to ensure HQS inspections were performed timely. Questioned costs: Unable to determine. Context: During our testing of 40 files over HQS inspections, we noted the following: 21 of 40 units tested had an inspection that was not performed on a biennial basis as determined in the Administrative Plan. Cause: The Commission did not work closely with the inspection company with poorly written procedures in place for documenting inspections. The Commission experienced challenges during COVID in completing inspections timely. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
2022-004 ? HQS Failed Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Housing Choice Voucher Program FALN: 14.871/14.879 Federal Award Identification Number and Year: MD023, 2022 Award Period: 1/1/2022-12/31/2022 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) HAPs beginning no later than the first of the month following the specified incorrect period or must terminate the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition: We noted that the Commission did not properly abate HAP for landlords in which units failed inspections. Questioned costs: $69,944 Context: During our testing of 40 files for HQS enforcement, we noted the following: 10 of 40 units tested failed inspection due to owner responsibilities and the Commission never abated HAP. 5 of 40 units tested failed due to tenant responsibilities and the Commission did not take proper steps to enforce family obligations. Cause: The Commission did not follow established procedures in their Housing Choice Voucher Administrative Plan or as required by HUD. Effect: The Commission is not in compliance with HUD requirements. Repeat finding: No Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.