Corrective Action Plan For the year ended September 30, 2022 U.S. Department of Housing and Urban Development: Housing Authority of the City of Salem respectfully submits the following corrective action plan for the year ended September 30, 2022. Auditor: Novogradac and Company, LLP Certified...
Corrective Action Plan For the year ended September 30, 2022 U.S. Department of Housing and Urban Development: Housing Authority of the City of Salem respectfully submits the following corrective action plan for the year ended September 30, 2022. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the September 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Federal Award Findings and Questioned Costs Finding 2022-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria:Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,723 Section 8 Housing Choice Vouchers units and 123 Mainstream Vouchers units. Of a sample size of forty-seven (47) tenant files, the following was noted: ? Lead based paint form was missing in 14 files ? Annual inspection report was missing in 1 file Our sample size is statistically valid. Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation:We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendations of the auditor and has issued the following directives to staff in order to prevent future recurrence of similar issues: ? Administrative Advisory 2023-02 ? This Administrative Advisory requires staff, effective June 12, 2023, to obtain the Lead Based Paint (LBP) Disclosure form for any new leases / moves related to units built before 1978, as well as requiring staff to review files at annual recertification and request the LBP Disclosure form for those units built prior to 1978 as part of the recertification process. Using this method, all LBP disclosures shall be present in tenant files by the end of calendar year 2025 (SHA is moving to biennial recertifications as part of its Moving to Work Initiative). ? Administrative Advisory 2023-03 ? This Administrative Advisory directs staff to ensure that original applications and initial eligibility documentation are scanned when files are archived, or new volumes are created. Additionally, staff have been advised to pull the original application and initial eligibility forward into new volumes. If the original application and initial eligibility information are found to be incomplete or missing at the time the file is archived, staff have been instructed to document the file and replace the missing information with the best available documentation to demonstrate date of original application and that initial eligibility criteria were met. Due to the conditions of the COVID-19 pandemic, SHA was unable to contract a third party inspector to conduct inspections of units that it owns and operates, as required by HUD regulations. This led to a gap of more than 24 months between an initial inspection and a biennial inspection for a resident living in a SHA-owned unit. Inspections of SHA-owned units have since been completed under an agreement with a neighboring housing authority and will continue to be completed in accordance with HUD regulations and requirements going forward. Melanie Fletcher will be responsible to implement this corrective action by September 30, 2023.