FAC Explorer

Finding 11259 (2022-002)

Material Weakness
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2024-02-01
Audit: 15062
Organization: Pittsfield Housing Authority (RI)
Auditor: Marcum LLP

AI Summary

  • Core Issue: The Authority failed to conduct necessary rent reasonableness assessments, violating HUD requirements.
  • Impacted Requirements: The lack of assessments means HAP payments may not be reasonable, risking compliance with federal regulations.
  • Recommended Follow-Up: Implement a recertification checklist to ensure all required documentation is collected for tenant files.

Finding Text

2022-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507) CONDITION The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned costs - $3,874,736. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

2022-002–Rent Reasonableness Determination–ALN14.871– Housing Voucher Cluster Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. Rent reasonableness determinations are now being made for all participants prior to initial HAP contract execution and in conjunction with any requested rent increases. Planned Implementation Date of Corrective Action Reminders to Staff regarding appropriate verification of all income: Completed Updates to Section 8 Administrative Plan and ACOP: 12/31/23 Retraining of staff, checklists and QC audit procedures: 6/30/24 Person(s) Responsible for Corrective Actions Paul Dettman, PHA Consultant: Tracy Pero, Section 8 Staff Leased Housing Program Manager Senior Public Housing Manager

Categories

Questioned Costs HUD Housing Programs Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 11258 2022-001
    Material Weakness
  • 11260 2022-003
    Material Weakness
  • 11261 2022-004
    Material Weakness
  • 11262 2022-004
    Material Weakness
  • 587700 2022-001
    Material Weakness
  • 587701 2022-002
    Material Weakness
  • 587702 2022-003
    Material Weakness
  • 587703 2022-004
    Material Weakness
  • 587704 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $4.45M
14.850 Public and Indian Housing $61,904
14.872 Public Housing Capital Fund $55,309