Finding 1157010 (2024-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369314
Auditor: Cbiz CPAS PC

AI Summary

  • Core Issue: The PHA failed to properly verify and calculate tenant income, leading to inaccuracies in housing assistance payments.
  • Impacted Requirements: Annual reexaminations and third-party verifications of income and assets were not consistently documented or calculated correctly.
  • Recommended Follow-Up: Strengthen policies and procedures to ensure all necessary documentation and annual recertifications are completed and maintained in tenant files.

Finding Text

2024-002 – ELIGIBILITY – ELIGIBILITY FOR INDIVIDUALS Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development ALN #: 14.871 – Housing Choice Voucher Program CRITERIA The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: (i) Reported family annual income; (ii) The value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income. (2 CFR 982.516 (a)) (1) As a condition of admission to or continued assistance under the program, the PHA shall require the family head, and such other family members as the PHA designates, to execute a HUD-approved release and consent form (2 CFR 982.516(g)) CONDITION As a result of our testing, we identified the following: • Six instances in which the PHA obtained sufficient verifications of income; however, the PHA calculated the annualized tenant income incorrectly or it was unclear how the PHA calculated annualized income. • Four instances of an incorrect payment standard being used. • Four instances in which HUD’s Enterprise Income Verification system was not used. • One instance of a missing release and consent form (HUD-9886) • One instance of an insufficient verification of income. CAUSE The Authority's system of obtaining and documenting third-party verifications of tenant’s income, assets, or deductions was not sufficient EFFECT The Authority did obtain proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby housing assistance payments. QUESTIONED COSTS None Noted. CONTEXT The Authority leased approximately 320 vouchers through the Housing Choice Voucher Program throughout the year. We selected a sample of 40 participant files. This was not a statistically valid sample REPEAT FINDING This finding is repeated from finding 2023-002. RECOMMENDATION We recommend policies and procedures are strengthened to ensure all proper documentation and annual recertification are maintained in all tenant files to document eligibility. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

Auditee’s Response and Corrective Action 2024-002- Eligibility- Eligibility for Individuals (HCV) Response: Existing filing errors have been corrected. VHA will ensure/ demonstrate the accuracy of future filings with respect to income calculations, UA credits and allowances of HAP contracts. Vernon Housing has implemented the following: The agency FY 2024 audit noted fewer file issues as sample errors pointed out in FY 2023 have been corrected and reviewed with associated personnel. Vernon Housing Authority has a quality control program to ensure that all HCV files are complete and up to date. Since the beginning of 2024 and going forward into CY 2025 the Housing Programs Manager has reviewed all annual recertifications and interims completed by HCV associated staff for compliance and filing accuracy. In addition, structured filing and monthly quality control systems continue to be followed by HCV staff and program management. These are ongoing tasks that the program manager is responsible for overseeing. Management has implemented file management systems that are checked during monthly QA process to ensure proper file management. HCV program staff will continue to use file review checklist when performing annual and interim recertification procedures to ensure that the proper documentation is in the file. These are ongoing tasks that the program manager is responsible for overseeing. Management will continue to require staff to attend continued education trainings and obtain the necessary certifications for HCV staff requirements. Management will hold staff accountable for failure to adhere to the governing rules and regulations for file compliance. Planned Implementation Date of Corrective Action: October 2025 Person Responsible for Corrective Action: Shenoa Steves, Housing Programs Manager

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1157009 2024-001
    Material Weakness Repeat
  • 1157011 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $4.64M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $2.04M
14.850 Public Housing Operating Fund $686,105
14.872 Public Housing Capital Fund $259,031