2025-004 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Other matter required to be reported in accordance with Uniform Guidance (Repeated in part from prior year, Finding No. 2024-004) Condition: Out of a population of 377 Housing Voucher Cluster tenants, we selected 40 t...
2025-004 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Other matter required to be reported in accordance with Uniform Guidance (Repeated in part from prior year, Finding No. 2024-004) Condition: Out of a population of 377 Housing Voucher Cluster tenants, we selected 40 tenants for testing and the following deficiencies were noted: • 6 files had incorrect income calculations, 5 of which impacted the HAP received; • 2 files were missing signatures on their 9886 form; • 2 files were missing 214 declarations for members of the household; • 1 file was missing identification for adults and dependents in the household; • 1 file had the incorrect utility allowance applied; • 1 file was delayed in receiving an annual recertification (13-month recertification); and, • 1 file did not have an annual recertification performed when due, and not able to be provided for testing. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: Management acknowledges the findings and the material weakness in internal control for eligibility. We accept responsibility for the deficiencies in internal control over eligibility and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • CHA will perform a 100% review of all remaining Housing Choice Voucher participant files not included in the audit sample to determine whether the deficiencies identified are isolated or systemic. Any additional errors or missing documentation discovered during that review will be corrected promptly, and any financial impact will be evaluated. • Correct utility allowances are being applied. • CHA has begun to review and correct all deficiencies identified in the auditor’s sampled files. This includes obtaining missing documents where possible, completing or correcting forms, verifying income, utility allowances, payment standards, inspections, rent reasonableness, identification documents, and 50058 submissions. Any unsupported payments or eligibility determinations will be recalculated and resolved. • CHA uses a mandatory file documentation checklist for all new admissions, interim recertifications, annual recertifications, moves, and contract rent changes. • No file will be finalized and no HAP action processed until a supervisor or designated reviewer verifies completeness, accuracy, and compliance with HUD requirements. This review will be documented and retained in the file. • With the implementation of new housing software in the late summer of 2026, CHA will implement a software-based tickler system to monitor annual recertification due dates, interim actions, inspection due dates, and expiring documents. The system will provide advanced reminders to staff to ensure recertifications and related actions are completed within required timeframes. In addition, the same system will be used to improve inspection monitoring/tracking. • All Housing Choice Voucher staff involved in eligibility, recertifications, inspections, file maintenance, and payment processing will continue to receive training on HUD eligibility requirements, documentation standards, file retention, rent calculations, utility allowances, payment standards, rent reasonableness, and 50058 reporting. • Management will conduct periodic internal quality control reviews of tenant files throughout the year to test compliance and identify issues before year-end. Results of these reviews will be documented, discussed with staff, and used to provide additional coaching or corrective action where needed. Name of Responsible Person(s): Jackie Otto, Executive Director, Sherdana Wade, Director of Operations, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate full compliance ahead of the June 30, 2027 audited submission.