Finding 1160443 (2023-005)

2023-005 Eligibility – Tenant Files Public and Indian Housing Program – CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance This is a repeat finding of 2022-004, reported as a Material Weakness and Material Noncompliance from June 30, 2022 (initially occurred as Finding 2021-002, Material Weakness and Material Noncompliance) Condition: Out of a total tenant population of approximately 269 tenant files, 25 files were selected for testing. Exceptions were noted as follows: • 4 tenant files where the 214 Affidavit was not in the file or was incorrectly completed (2 files for missing 214 affidavits and 2 files where boxes were not checked to indicate adults were signing for dependents). • 5 tenant files where the tenant’s personal declaration form was missing for the time period tested. • 2 tenant files where the Form 9886 were missing for the time period tested. • 10 tenant files where there were income issues (including income calculation errors or missing support or missing Forms 50058). • 7 tenant files had deduction issues (several for deductions that were taken twice for food stamp income that was “excluded” and then deducted again, incorrect utility allowances, incorrect child care costs). • 1 tenant file where the Form 50058 was missing so unable to determine if recertification date was correct. • 4 tenant files with missing birth certificates • 1 tenant file where the tenant’s date of birth on the 50058 form did not match the tenant’s birth certificate. • 5 tenant files with missing social security cards. • 1 tenant file where the adult tenants did not sign the lease agreement. • 5 tenant files with missing EIVs. Auditor’s Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: As was also instituted for HCV participant files, the Authority has instituted a checklist sheet that will occupy the front interior of all tenant files. This checklist will contain every document that is required to be placed in the tenant file. The Authority has and will affirm the use of its procedures, and continue to implement procedures to ensure all tenant files are maintained in accordance with policies and procedures. Additionally: • All noted deficiencies will be corrected and cured. • The Authority has also taken steps to stabilize staff by hiring a Property Manager and an Occupancy Specialist that will support the Public Housing Department. • The Authority has implemented a 100% quality control review of all participant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured. Thereby reducing any additional findings with tenant files. • Repeated noted errors will be reported to the Senior Property Manager and additional hand's-on training regarding deficient items will be completed as necessary.