Finding 1160276 (2024-002)

Material Weakness Repeat Finding

Requirement

ELN

Questioned Costs

Year

2024

Accepted

2025-10-10

Audit: 370665

Organization: Housing Authority of the County of Chester (PA)

Auditor: Rubino & Company Chartered

AI Summary

Core Issue: The Authority failed to maintain essential tenant documentation, leading to noncompliance with federal housing program requirements.
Impacted Requirements: Missing eligibility declarations, signed release forms, annual recertifications, and timely submissions of HUD Form 50058.
Recommended Follow-Up: Enhance policies and internal controls to ensure all tenant files are complete and accurate, particularly for recertifications and documentation retention.

Finding Text

Finding 2024-002: Missing Tenant Information (Material Weakness, Material Noncompliance) Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Federal Assistance Listing Number: 14.871/14.879 Compliance Requirement: Eligibility, Reporting, Special Tests and Provisions Criteria: Per 2 CFR, PHAs are required to obtain documentation declaring the tenant is eligible to receive federal housing benefits, obtain release forms from tenants to gather necessary information from third parties, perform annual recertifications of tenant income through HUD Form 50058, and perform annual inspections of the units. Condition: The Authority was unable to provide declarations of eligible status, signed release forms, and annual recertifications. Furthermore, the Authority did not calculate income correctly to determine tenant’s rent amount. Context: Out of the 40 tenant files reviewed, we found the following exceptions:  5 files did not have proper declaration of eligible status  2 files did not have updated signed release forms  3 files did not have the annual inspection  11 HUD Form 50058s were not submitted on time  3 files did not have proper utility allowance calculations  3 files did not have income calculated correctly Effect: The Authority was not in compliance with the eligibility, reporting, and special tests and provisions requirements for the program. Cause: The Authority did not have the proper controls in place to ensure the files were complete and accurate. Repeat Finding: The inspection portion of this finding is a repeat finding; the other portions of this finding are not a repeat finding. Recommendation: The Authority should review and enhance its policies, procedures, and internal controls to ensure the recertifications are performed and the necessary documentation is adequately retained in the Authority’s files. Views of Responsible Officials: The Authority agrees with the finding.

Corrective Action Plan

Action Taken: Housing Authority of the County of Chester agrees with the above recommendations and has already instituted policies and procedures designed to address the findings. Please see the list of procedures. HACC Recertification & Documentation Checklist (Quick Reference – 1 Page) 1. Recertification Timeline • Annual: Start process 120 days before due date. • Interim: Complete within 30 days of household change. • Missed/Delayed: Notify Program Manager immediately and document reason. 2. Required Documentation • Income verification (pay stubs, benefits, child support). • Asset verification (bank/retirement statements). • Family composition docs (birth certificates, SSNs). • HUD-required forms. • Use EIV when available; seek third-party verification first. • All docs must be collected within 60 days of effective date. 3. File Standards • Use Resident File Checklist for each household. • Files must include all signed forms & verifications. • Store in approved secure system (electronic or paper). • Retain files 3 years after end of participation (longer if litigation/audit pending). 4. Internal Controls • Supervisory Review: 10% of files checked monthly. • Maintain clear audit trail (date notices, interviews, verifications). • Correct any deficiencies within 30 days. 5. Staff & Training • Staff handling certifications = annual HUD/HACC compliance training. • Document training completion in personnel file. 6. Monitoring • Quarterly compliance report on timeliness & file completeness. • Issues shared with Executive Director and Board. • Policies reviewed annually for updates. Roles • Housing Specialists: Complete recerts & file docs. • Supervisors: Monitor timeliness & review files. • Compliance Officer: Audit & reporting. • Executive Director: Oversight & resources. n Follow this checklist to ensure timely recertifications, complete documentation, and avoid audit findings.

Other Findings in this Audit

1160273 2024-001

Material Weakness Repeat
1160274 2024-002

Material Weakness Repeat
1160275 2024-002

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
14.879	Mainstream Vouchers	$2.35M
14.850	Public Housing Operating Fund	$1.72M
14.871	Section 8 Housing Choice Vouchers	$1.18M
21.027	Coronavirus State and Local Fiscal Recovery Funds	$837,379
14.872	Public Housing Capital Fund	$671,297
14.249	Section 8 Moderate Rehabilitation Single Room Occupancy	$323,036
14.896	Family Self-Sufficiency Program	$74,460
14.870	Resident Opportunity and Supportive Services - Service Coordinators	$66,653