Finding Text
2024-002 Special Tests and Provisions – Program Administration Federal Award: U.S. Department of Housing and Urban Development (HUD) – Housing Choice Voucher Cluster (ALN 14.871/14.879) Finding: The Authority’s tenant files and program procedures did not fully comply with HUD documentation and administrative procedure requirements. Repeat Finding: Yes. Criteria: HUD has established various compliance and documentation requirements related to the use of Federal funds. These compliance and documentation requirements impact many areas of HUD compliance and reporting such as, but not limited to, program administration, tenant certifications and recertification procedures, tenant income eligibility, document retention requirements and documentation within tenant files. Sample Size and Population: Population of the program is 357 tenants of which 25 tenant files were selected for testing. An additional 10 files were selected for testing as noted in HUD’s monitoring letter dated May 23, 2024. Condition and context: In addition to the auditor file review procedures, the Authority was selected for a Comprehensive Compliance Monitoring Review by the HUD field office which issued a letter dated May 23, 2024 noting a number of instances of non-compliance with HUD program administrative requirements, tenant eligibility and documentation requirements. Of the combined 35 tenant files reviewed, the following instances of noncompliance with specific HUD compliance requirements were noted as follows: • Seven tenant files – Certain documentation required by HUD program requirements was not retained in the file. • Four tenant files – Subsidy amount determined by the Authority did not comply with HUD program requirements. • Four tenant files – Income verification procedures performed and documentation retained did not comply with HUD program requirements. • Four tenant files – Asset verification procedures performed and documentation retained did not comply with HUD program requirements. • Two tenant files – Rent increase notices did not comply with the 30 day notification requirement • One tenant file – The lease agreement did not conform to HUD requirements • One tenant file – The utility allowance did not agree to the HUD-52580 In addition, in the Comprehensive Compliance Monitoring Review letter dated May 23, 2024 identified a number of administrative areas of non-compliance as well as some errors and inconsistencies with information reported through the PIH Information Center (PIC) Error and Voucher Management System (VMS). Cause: The Authority process and procedures were inconsistent with established HUD program requirements. Effect: The Authority did not comply with HUD program requirements regarding program administration, tenant certifications and recertification procedures, tenant income eligibility, document retention requirements. Recommendation: The Authority should review, update and modify its established program process and procedures to fully comply with established HUD program requirements. Questioned Costs: None Management Response: Management agrees with the finding and we have prepared a response which is reported in the “Corrective Action Plan” at the end of this report. As noted in our Corrective Action Plan, the Authority has fully responded to the Comprehensive Compliance Monitoring Review and corrected the various deficiencies noted in the report. The Authority received notification on October 30, 2024 that HUD has accepted the Authority’s response and resolution of the deficiencies noted and that the matter is closed. Contact Person: Nancy Nash Mendez, Executive Director