Reference Number: 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Significant Deficiency ...
Reference Number: 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Authority’s Response & Actions Taken The Authority has taken substantial and measurable steps to address the prior backlog of annual reexaminations, including stabilizing third-party administration and implementing earlier and more structured reexamination processes. As a result of these efforts, all reexaminations identified during the audit period were ultimately completed, and all households were confirmed eligible with accurate housing assistance payments prior to the end of FY2025. The Authority’s current procedures—such as initiating reexaminations 150 days in advance, conducting weekly monitoring, and coordinating closely with property management and service providers—have significantly improved overall performance and strengthened operational consistency. The remaining instances of untimely reexaminations reflected in the audit are largely attributable to tenant non-responsiveness and timing factors associated with the audit sample period, during which a portion of cases were still in process despite being actively worked on and subsequently completed. These results do not fully reflect the progress achieved or the Authority’s current operational status. The Authority maintains a tenant-centered approach to program administration, ensuring that eligible households are not unnecessarily terminated due to documentation delays (this is especially important with the Authority being in shortfall which does not allow for voucher reinstatements). This approach is supported by structured outreach, enforcement protocols, and documented follow-up actions. The Authority continues to work diligently with its third-party HCV contractors, city department partners, onsite service providers and property management companies to ensure timely recertification of all assisted households. At the same time, the Authority has strengthened internal controls to better align tenant flexibility with HUD timeliness requirements. The Authority continues to enhance oversight, tracking, and contractor accountability to ensure sustained compliance with HUD standards. The enhanced oversight and monitoring resulted in SEMAP fiscal year end 9/30/2025 with High Performer status, and current performance trends show the Authority is well positioned to maintain SEMAP High Performer status for the current fiscal year. Specifically for SEMAP Indicator 9 for Annual Reexamination, the Authority achieved 5 out of 10 points for fiscal year end 9/30/2025, which was an improvement from the prior fiscal year of 0 out of 10 points, and currently trending in a positive direction to achieve 10 out of 10 points for FY2026. The corrective actions outlined below are designed to ensure that tenant-related delays are minimized, documented, and managed in a way that prevents the recurrence of this material weakness. To address this finding and in accordance with the Authority’s Administrative Plan and HUD rules and regulations, the Authority has already implemented the following actions starting fiscal year 2023-24: For the Project-Based program: Two project-based households were cited for late re-exams in relation to finding 2025-001. Prior to this year’s audit, those households were identified and brought into compliance prior to the end of FY2025. In addition to the actions taken in last year’s corrective action plan for finding 2024-002, the Project-Based Voucher Program has begun: Scheduling second notice in-person appointments for households who do not return the Annual Re-examination package in the required timeframe from the first mailing. Maintaining a live shared log of delinquent Annual Re-examinations which the property managers have access to. Including resident services and property management in the intent to terminate process to emphasize the importance of compliance and provide direct support to the resident. Streamlining Annual Re-examinations for senior and/or disabled households with fixed incomes through the triennial process. Scheduling and completing on-site visits for senior-disabled sites and non-restricted sites with large numbers of families out of compliance. Continuing to review discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. For the Tenant-Based Program: Two tenant-based households were cited for late re-exams in relation to finding 2025-001. Prior to the end of FY2025, each household was brought into compliance and had their annual reexaminations completed. In addition to the actions taken in last year’s corrective actions plan for finding 2024-002, the Tenant-Based Program has begun: Updating the administrative plan to allow for verification of documents to be dated with 120- days of submittal instead of 60-days which allows more flexibility and less likelihood of needing additional items from the client. Tracking annual reexaminations for each assigning housing specialist the moment packets are mailed and throughout the process, both through individual tracking sheets and the Authority's Customer Relations Management system. Housing Authority 2025 Corrective Action Plan Page 4 of 6 Tracking late re-exams on the management level on a monthly basis and following up with the individual housing specialists. Utilizing case managers for special programs to assist with outreach and completion of the paperwork. Reviewing previous annual reexamination and HUD’s supplemental 92006 form to determine if the household has identified an individual to contact for assistance with the annual reexam and contacting them. Continuing to review discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. Anticipated Implementation Date September 30, 2026 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations