Finding No. 2023-014
Department(s): New York City Housing Preservation & Development
Program(s):
Assistance Listing Numbers:
14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy
14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance P...
Finding No. 2023-014
Department(s): New York City Housing Preservation & Development
Program(s):
Assistance Listing Numbers:
14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy
14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation
Corrective Action(s):
During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow-up to ideally have participants comply with requirements (but if necessary to terminate assistance for those who do not comply). Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance.
Corrective Action(s):
1. Build on existing systems to more closely track recertifications that are mailed and not returned.
2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications.
3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package.
4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely.
5. Invest in a training team to meet the training needs of new staff.
Anticipated Completion Date: April 2025
Person(s) Responsible for Implementation:
Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability
FIKRUD@hpd.nyc.gov