Finding 2023-001 – Housing Choice Voucher Program Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness - Housing Choice Voucher Program - subsidy ALN #14.871
Corrective Action Plan:
Finding 2023-001 for the most part correctly identifies the cause of...
Finding 2023-001 – Housing Choice Voucher Program Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness - Housing Choice Voucher Program - subsidy ALN #14.871
Corrective Action Plan:
Finding 2023-001 for the most part correctly identifies the cause of this finding: “We noted that the Authority has experienced difficulty in hiring, training, and retaining quality staff. This is the cause for each of the instances of noncompliance referenced.” The “Great Resignation” during the pandemic affected the HCV Program significantly as staff began to search for other opportunities and potential staff did not find RHA’s compensation competitive.
Other negative impacts related to the pandemic included the moratorium on evictions and termination of assistance. Participants had fewer incentives to comply and became lax, resulting in increased levels of work to counter this lax attitude towards program rules. Later in 2022, the end of moratoria resulted in RHA’s voucher utilization rates plummeting as landlords exercised their rights to evict and terminate as well as pursuing rapidly increased market rents instead of renewing leases of voucher participants or renting to voucher holders for the first time. The efforts to retain landlords and issue hundreds of vouchers strained the departments’ staffing resources.
The underlying cause of the findings was not just the pandemic effects. RHA recognized that it had underinvested in program operations. First, compensation levels were not close to being competitive. Second, RHA did not invest enough in staff training, a key factor in retention. Third, RHA had also underinvested in technology, using inefficient systems and paper-intensive operations. Fourth, in addition to underinvesting in compensation, RHA also did not allocate resources to staffing, resulting in an understaffed department—managers and line staff. And fifth, these areas of underinvestment led to an organizational structure and staffing model that resulted in staff roles being very narrow. Multiple staff were involved in individual aspects of processes like annual recertifications. It did not require much training, and it relied on staff to do narrow repetitive tasks in a conveyor-belt fashion without anyone being accountable for an entire process. For example, between one and two staff were responsible for doing calculations for participants’ rent portion and subsidy amounts for 3,800 or so annual recertifications and scores of interim recertifications. Four “client specialists” were each responsible for facilitating almost 1,000 participants’ compliance with recertification requirements prior to the two account specialists’ calculation work.
In 2023, RHA started to address the root cause that led to this and other findings—underinvestment:
1. RHA’s Human Resources issued an RFP for a firm to do an analysis of compensation levels and make recommendations for classification of positions and competitive compensation. The study was completed and implemented effective the first pay period in December 2023. Individual compensation increases averaged more 10 percent, with staff in the operating departments like HCV benefiting from even higher salaries. These increases were on top of a five percent increase in all salaries effective July 1, 2023, in anticipation of the results of the study.
2. The Director of HCV immediately, upon direction to increase training, contracted with Nan McKay to provide HCV Specialist Certification training to all staff responsible for any part of the eligibility and ongoing occupancy processes. Prior to this effort, only one HCV staff member had been certified. All but one staff person failed the certification class. Going forward, all new staff will be required to pass Nan McKay’s HCV Specialist Certification class by the end of probation.
3. The HCV Director also contracted for Manager and Supervisor Training by Nan McKay for all supervisory staff. All completed certification requirements.
4. The HCV Director also recommended and implemented proposals to reorganize the department by ensuring that managers had a manageable supervisory load of not more than six staff per manager. The new structure created an eligibility unit headed by an eligibility manager (for the first time) as well as two units of ongoing eligibility staff of 12 HCV specialists overseen by two managers. These actions represent a significant increase in staffing and supervision. This reorganization also entails the implementation of a “case management” model in which each HCV Specialist is responsible and accountable for an initial case load of 300 voucher participants. Managers will be responsible for mentoring, training, quality control (file audits) and evaluation of the work of their staff. This reorganization of the department reflects multiple strategies to address some of the root causes that gave rise to the audit finding.
5. By the time the new CEO came on board on April 17, 2023, RHA had completed the evaluation of bids for new software and selected YARDI’s Voyager, Rent Café portals, and other applications to replace antiquated systems. Contract negotiations between RHA and YARDI were completed in July 2023. This initiative represented both a commitment to far greater efficiency and accuracy as well as a willingness to invest in program operations. Implementation and setup are well underway and April 1, 2024, is the “go-live” date. Needless to say, this commitment of resources and countless hours of staff time over nine months has had short-term impacts on RHA’s ability to address identified weaknesses. However, RHA is committed to long-term benefits while enduring short-term pain.
These investments in a comprehensive strategic plan for long-term improvements in customer service, compliance, and performance will yield positive results without necessarily making major progress over the short term. To effect improvements over the short term, RHA has implemented the following measures:
1. The HCV director contracted with Nan McKay to assist RHA with catching up on compliance work that has stalled as a result of short staffing and lack of trained staff. Nan McKay’s own difficutly in retaining trained staff and hiring and training new staff delayed their assistance. This delay was further exacerbated by cyber event at the beginning of May 2023. RHA’s computers and systems were locked down by a threat actor requiring ransom. This event reduces RHA operations to manual processes and lack of access to key information to perform compliance work.Nan McKay’s efforts to assist are increasing over time.
2. HCV managers are increasing their efforts to perform qualify control efforts, focusing their staff’s attention on enforcing participants’ compliance with program requirements, including deadlines, and using what they learned from their training.
Person Responsible: Priscilla Batts, HCV Director, is principally responsible and accountable for focusing her team on the strategic initiatives outlined above.
Anticipated Completion Date: Some of the corrective actions above have been implemented, for example, competitive compensation, training, and outsourcing some of the compliance work. However, these are mainly system changes that will be fully implemented in 2024, for example, new software, with significant improvements that will be evidenced by December 31, 2024.