Finding 1073208 (2023-001)

Finding 2023-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021 (2021-001) and 2022 (2022-001) Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted 4 instances where a tenant recertification using the HUD-50058, Family Report (OMB No. 2577-0083) form (which provides eligibility and reporting information) was either not completed, or not completely on a timely basis. We also noted multiple instances where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 that we were able to review was not provided. This includes items such as rent reasonableness forms, support for income calculation, signed and approved HAP contracts and lease agreements, and signed HUD Form 9886. Criteria: The Authority is required to prepare and submit HUD-50058 form each time the Authority completes an admission, annual reexamination, portability move-in, or other change of unit for a family. The form provides HUD and the Authority with vital eligibility data for each program participant such as family composition, family income, the assets and liabilities of program participants, and ultimately provides for the calculation of tenant rent and rental/housing assistance payments for each program participant. In relation to the missing documents noted above, these documents are to be maintained to support the eligibility of the tenant, and are also required to be maintained to provide support for the tenant income and eligibility determinations completed on the HUD-50058 form. The signed lease and HAP contracts are also required to ensure appropriate amounts are used in calculation subsidy payments, and appropriate payments are made to landlords for the housing provided. Cause: There was a lack of functioning internal control over the recertification process that were exacerbated by turnover and logistical staffing challenges. Effect: HUD-50058 forms provide essential information to HUD as well as being used by the Authority to determine program eligibility. In addition, the HUD-50058 form is used for the calculation of tenant rent and rental/housing assistance payments. Without this required documentation, this could lead to ineligible tenants being housed through the Authority program, and/or overpayments or underpayments of rental assistance, and incorrect information being reported to HUD. Questioned Costs: Unknown Recommendation: We recommend that the Authority implement additional procedures to ensure biennial recertification and the related HUD-50058 forms are prepared timely and accurately and that all supporting documentation is obtained and retained. In addition, appropriate training and planning should be performed to ensure that future turnover in the organization does not lead to a lapse in internal controls over compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.