2025-002 Housing Choice Voucher Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters This is a repeat finding of 2024-003 from September 30, 2024 (Original...
2025-002 Housing Choice Voucher Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters This is a repeat finding of 2024-003 from September 30, 2024 (Originally reported as Material non-compliance and Material Weakness in Internal Control over Compliance under finding 2019-001 from September 30, 2019) Statement of Condition: Out of a total tenant population of approximately 1,086 leased vouchers, 25 files were selected for testing, and the following errors were discovered. • 1 tenant file where the tenant's utility allowance was miscalculated and reported incorrectly on the 50058 form. Correcting this error would decrease the HAP rent by $26. • 1 tenant file where the tenant's utility allowance was miscalculated and reported incorrectly on the 50058 form. Correcting this error would decrease the HAP rent by $23. • 1 tenant file where the tenant's income was miscalculated and reported incorrectly on the 50058 form. Correcting this error would decrease the HAP rent by $266. • 1 tenant file where the tenant's income was miscalculated and reported incorrectly on the 50058 form. Correcting this error would decrease the HAP rent by $40. • 1 tenant file where the tenant's income was miscalculated and reported incorrectly on the 50058 form. Correcting this error would decrease the HAP rent by $318. • 1 tenant file where the tenant’s utility allowance and income was miscalculated and reported incorrectly on the 50058 form. Correcting this error would decrease the HAP rent by $121. • 1 tenant file where the tenant’s income was miscalculated but did not impact the HAP rent. • 1 tenant file where the tenant’s wage income was coded incorrectly as federal income on the 50058 form. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority has corrected all deficiencies identified in the files reviewed during the audit. To further strengthen compliance and reduce the likelihood of future errors, several corrective actions have been implemented. The Authority has enhanced its quality control procedures by implementing a systematic file review process. At a minimum, every fifth file processed receives a quality control review to verify the accuracy of third-party verifications, income determinations, utility allowance, and subsidy calculations. In addition, management conducts monthly reviews of at least ten percent (10%) of each Housing Counselor's annual recertifications, with the percentage increased as warranted based on performance trends or identified deficiencies. The HCV Program Manager also reviews a minimum of one out of every five intake files, while all new admissions and move-in files are reviewed by the Compliance Director prior to approval. The Compliance Director additionally conducts monthly compliance reviews of a ten percent (10%) sample of processed files. To improve consistency and reduce calculation errors, the Authority developed and implemented a Family Worksheet and an HCV Computation Worksheet. These tools assist staff in verifying household composition, income calculations, and subsidy determinations prior to the completion of annual reexaminations and interim recertifications. The Authority has also revised its filing system to facilitate more comprehensive reviews of participant documentation during admissions, annual recertifications, and interim adjustments. To ensure compliance with citizenship and eligibility requirements, the Authority created an “Other Adult” packet that includes Form HUD-214 declarations and other required documentation for all adult household members. In addition, HCV Counselor caseloads have been redistributed equitably to improve efficiency, workload management, and accuracy. Caseloads are assigned alphabetically and by multifamily developments, allowing management to more effectively monitor performance, identify training needs, and provide targeted oversight where necessary. Specialty voucher programs, including Emergency Housing Vouchers (EHV), Veterans Affairs Supportive Housing (VASH), Family Unification Program (FUP), and Homeownership vouchers, have been assigned to a dedicated Counselor with specialized training, experience, and responsibility for those programs. Management of all Family Self-Sufficiency (FSS) participants has been assigned exclusively to the FSS Coordinator. To strengthen the admissions process, the Authority established an Intake Housing Counselor/Portability Specialist position responsible for determining applicant eligibility, managing the waiting list, and processing portability clients. While the Authority has experienced significant turnover in this position, including three staff changes within the past two years, management recognizes the challenges associated with onboarding and training new staff and has taken steps to improve oversight and support during transition periods. The Authority has also experienced significant turnover within the HCV Department over the past twenty-four months. All current HCV Counselors, with the exception of the newest Intake Counselor, have less than six months of tenure and were not members of the HCV team during the FY 2025 audit period. To ensure staff are fully equipped to administer the program in accordance with HUD requirements, all HCV Counselors will participate in formal external training through Nan McKay & Associates within the next six months, supplemented by ongoing internal training, mentoring, and supervisory review. The Authority believes these corrective actions significantly strengthen internal controls and program oversight and demonstrates its commitment to continuous improvement, regulatory compliance, and the accurate administration of the Housing Choice Voucher Program.