Audit 52919

FINDING No. 2022-001: Section 8 Housing Assistance Payments Program, CFDA 14.195 Finding Resolution Status: Unresolved. Information on Universe Population Size: One hundred and seventy tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: Yes, 2021-001. Criteria: HUD regulations require management to maintain tenant files containing an apartment application signed and dated when received, all lease addenda signed by the tenant and owner, background checks performed prior to the tenant moving in, Enterprise Income Verification (EIV) performed within 90 days of the tenant being entered into Tenant Rental Assistance Certification System (TRACS), and move-in unit inspection reports signed by the tenant and owner. Statement of Condition: Five tenants were missing an apartment application signed and dated when received, one tenant was missing the VAWA lease addendum, one tenant was missing a criminal background check, fourteen tenants were missing an initial EIV report, one tenant did not sign the move-in unit inspection, one tenant did not have the move-in unit inspection appropriately filled out, and one tenant was missing a move-in unit inspection report. Cause: The manager did not maintain appropriate tenant eligibility documentation in accordance with HUD requirements. Effect or Potential Effect: Unable to determine date and time for the receipt of applications for proper waiting list placement and subsequent selection to occupy a unit. In addition, improper maintenance of tenant files and not verifying tenant eligibility in accordance with HUD requirements can result in the cost of assistance and residency being disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure all documentation related to applicants and tenants are properly executed and maintained, and that the manager verifies eligibility by obtaining all required documents for potential tenants while verifying and maintaining support for tenant income eligibility through the EIV system in a timely manner. Response Indicator: Agree. Completion Date: 9/30/2023 Response: Individual and group training will be conducted with managers in following the proper procedures when taking applications and moving in a new tenant. Going forward Compliance has arranged to review the move-in files for Council House to ensure all required forms are signed and dated. Alerts have been activated in One Site to remind managers when it is time to pull the initial EIV Income Report.

FINDING No. 2022-002: Section 8 Housing Assistance Payments Program, CFDA 14.195 Finding Resolution Status: Resolved. Information on Universe Population Size: Rent schedules. Sample Size Information: Rent schedules. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD approved OCAF rent increases should be recognized in the period of approval with timely adjustments applied to the monthly housing assistance payments requests on form HUD-52670. Statement of Condition: The Project incorrectly recognized a prior year approved gross rent change in the current year, which resulted in material federal awards not being captured and reported on the SEFA in the correct period as well as a qualified opinion due to the identified material weakness over major program compliance. Cause: The Project materially understated reported housing assistance payments on the prior year SEFA. Effect or Potential Effect: The Project was not able to utilize the additional funds awarded through the approved rent increase in the intended period and reported federal awards were materially misstated. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations have been adopted. Recommendation: The Project should implement procedures to ensure that rent increases are submitted for approval in a timely manner and that all approved gross rent changes are applied and captured in the period of approval. Response Indicator: Agree. Completion Date: 4/22/2022 Response: In 2023, Compliance will be beginning to monitor rent increases to ensure they are submitted timely. Compliance will also be monitoring approved gross rent changes to ensure that new rents are applied timely.

FINDING No. 2022-003: Section 8 Housing Assistance Payments Program, CFDA 14.195 Finding Resolution Status: Unresolved. Information on Universe Population Size: Twenty-two moved-in tenants. Sample Size Information: Two moved-in tenants. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD regulations require the maintenance of a waiting list and the selection of applicants in chronological order of application date with adequate documentation of the reasoning for an applicant being passed over for an applicant with a later application date. Statement of Condition: Five applicants were passed over without maintaining and documenting a reason. Cause: The manager did not maintain appropriate documentation of the reasons for passing over applicants. Effect or Potential Effect: Unable to determine date and time for the receipt of applications for proper waiting list placement and subsequent selection to occupy a unit. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure appropriate documentation of the reasoning for passing over applicants. Response Indicator: Agree. Completion Date: 9/30/2023 Response: Training in waiting list procedures has been conducted with managers. It is EHDOC policy that when passing over an applicant on the waiting list there must be proper notes in One Site and appropriate documentation in the applicant file. Random applicant files will be reviewed to ensure proper procedures are followed.

FINDING No. 2022-001: Section 8 Housing Assistance Payments Program, CFDA 14.195 Finding Resolution Status: Unresolved. Information on Universe Population Size: One hundred and seventy tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: Yes, 2021-001. Criteria: HUD regulations require management to maintain tenant files containing an apartment application signed and dated when received, all lease addenda signed by the tenant and owner, background checks performed prior to the tenant moving in, Enterprise Income Verification (EIV) performed within 90 days of the tenant being entered into Tenant Rental Assistance Certification System (TRACS), and move-in unit inspection reports signed by the tenant and owner. Statement of Condition: Five tenants were missing an apartment application signed and dated when received, one tenant was missing the VAWA lease addendum, one tenant was missing a criminal background check, fourteen tenants were missing an initial EIV report, one tenant did not sign the move-in unit inspection, one tenant did not have the move-in unit inspection appropriately filled out, and one tenant was missing a move-in unit inspection report. Cause: The manager did not maintain appropriate tenant eligibility documentation in accordance with HUD requirements. Effect or Potential Effect: Unable to determine date and time for the receipt of applications for proper waiting list placement and subsequent selection to occupy a unit. In addition, improper maintenance of tenant files and not verifying tenant eligibility in accordance with HUD requirements can result in the cost of assistance and residency being disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure all documentation related to applicants and tenants are properly executed and maintained, and that the manager verifies eligibility by obtaining all required documents for potential tenants while verifying and maintaining support for tenant income eligibility through the EIV system in a timely manner. Response Indicator: Agree. Completion Date: 9/30/2023 Response: Individual and group training will be conducted with managers in following the proper procedures when taking applications and moving in a new tenant. Going forward Compliance has arranged to review the move-in files for Council House to ensure all required forms are signed and dated. Alerts have been activated in One Site to remind managers when it is time to pull the initial EIV Income Report.

FINDING No. 2022-002: Section 8 Housing Assistance Payments Program, CFDA 14.195 Finding Resolution Status: Resolved. Information on Universe Population Size: Rent schedules. Sample Size Information: Rent schedules. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD approved OCAF rent increases should be recognized in the period of approval with timely adjustments applied to the monthly housing assistance payments requests on form HUD-52670. Statement of Condition: The Project incorrectly recognized a prior year approved gross rent change in the current year, which resulted in material federal awards not being captured and reported on the SEFA in the correct period as well as a qualified opinion due to the identified material weakness over major program compliance. Cause: The Project materially understated reported housing assistance payments on the prior year SEFA. Effect or Potential Effect: The Project was not able to utilize the additional funds awarded through the approved rent increase in the intended period and reported federal awards were materially misstated. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations have been adopted. Recommendation: The Project should implement procedures to ensure that rent increases are submitted for approval in a timely manner and that all approved gross rent changes are applied and captured in the period of approval. Response Indicator: Agree. Completion Date: 4/22/2022 Response: In 2023, Compliance will be beginning to monitor rent increases to ensure they are submitted timely. Compliance will also be monitoring approved gross rent changes to ensure that new rents are applied timely.

FINDING No. 2022-003: Section 8 Housing Assistance Payments Program, CFDA 14.195 Finding Resolution Status: Unresolved. Information on Universe Population Size: Twenty-two moved-in tenants. Sample Size Information: Two moved-in tenants. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD regulations require the maintenance of a waiting list and the selection of applicants in chronological order of application date with adequate documentation of the reasoning for an applicant being passed over for an applicant with a later application date. Statement of Condition: Five applicants were passed over without maintaining and documenting a reason. Cause: The manager did not maintain appropriate documentation of the reasons for passing over applicants. Effect or Potential Effect: Unable to determine date and time for the receipt of applications for proper waiting list placement and subsequent selection to occupy a unit. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure appropriate documentation of the reasoning for passing over applicants. Response Indicator: Agree. Completion Date: 9/30/2023 Response: Training in waiting list procedures has been conducted with managers. It is EHDOC policy that when passing over an applicant on the waiting list there must be proper notes in One Site and appropriate documentation in the applicant file. Random applicant files will be reviewed to ensure proper procedures are followed.