Finding 1162846 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2025-11-24

AI Summary

  • Core Issue: 17.1% of tenant files reviewed had errors in income verification and documentation.
  • Impacted Requirements: Noncompliance with HUD regulations on income verification and the Agency’s policy on quarterly EIV reviews.
  • Recommended Follow-Up: Implement a systematic review process for tenant files, enhance staff training, and ensure adherence to the Admissions and Continued Occupancy Policy.

Finding Text

Finding 2025-002 – Low Rent Public Housing Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Low Rent Public Housing – ALN 14.850 Condition & Cause: Our review of 35 Public Housing tenant files identified noncompliance in 6 files (17.1%). Of these, 2 files (5.7%) contained errors related to the verification of adjusted annual income. Both overall and income-related error rates increased compared to the prior year. Specific findings include: 1 file missing proper income verification 1 file missing proper deduction verification 3 files missing the EIV report for reexaminations 1 file missing support for an annual unit inspection 3 files missing a quarterly EIV review for zero-income households Contributing factors include insufficient quality control review procedures, high turnover in key leadership positions, and an ongoing transition to electronic tenant file systems. Criteria: HUD regulations (24 CFR § 5 and § 960) require accurate verification of income and deductions, documented annual reexaminations, and annual unit inspections. The Agency’s Admissions and Continued Occupancy Policy (ACOP) requires quarterly EIV reviews for households reporting zero income. All relevant documentation must be maintained in tenant files. Effect: Missing or inaccurate verifications and documentation may result in incorrect rent determinations, noncompliance with HUD requirements, and potential financial exposure. These issues may also impact program integrity and increase the risk of audit or monitoring findings. Recommendation: We recommend that the Authority establish a systematic review process for tenant files to ensure accuracy. This process should incorporate comprehensive staff training in correct verification methods and include regular quality control checks to promptly identify and correct errors. Furthermore, the Authority should ensure stricter adherence to its ACOP. Questioned Costs: None Repeat Finding: Yes Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

Finding 2025-002 – Low Rent Public Housing Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Low Rent Public Housing – ALN 14.850 Corrective Action Plan: 1. Income & Deduction Verification • Correct and update affected files immediately • Implement a standardized verification checklist • Conduct staff training on HUD documentation standards Person(s) Responsible: Occupancy Specialist / Selena Kelly, Interim Director of Property Management Start Date: September 26, 2025 Anticipated Completion Date: October 26, 2025, and ongoing 2. EIV Reports for Reexaminations • Retrieve and file missing EIV reports • Integrate EIV generation into reexamination workflow • Schedule quarterly audits for EIV compliance Person Responsible: Property Manager/ Selena Kelly, Interim Director of Property Management Start Date: September 26, 2025 Anticipated Completion Date: October 26, 2025, and ongoing 3. Annual Unit Inspection Documentation • Complete and document overdue inspection • Launch centralized inspection tracking • Assign monthly compliance checks to property managers and property staff Person(s) Responsible: Property Manager / Maintenance Supervisor Start Date: September 26, 2025 Anticipated Completion Date: October 26, 2025, and ongoing 4. Quarterly EIV Reviews for Zero-Income Households • Complete and document overdue reviews • Flag zero-income households for quarterly alerts • Provide refresher training on ACOP requirements Person(s) Responsible: Occupancy Specialist / Selena Kelly, Interim Director of Property Management Start Date: September 26, 2025 Anticipated Completion Date: October 26, 2025, and ongoing Monitoring & Follow-Up: • Conduct a follow-up audit of 10% of tenant files within 60 days • Include compliance updates in monthly management meetings • Report on progress to the Director of Property Management Person(s) Responsible: Selena Kelly, Interim Director of Property Management Start Date: September 26, 2025 Anticipated Completion Date: October 26, 2025 and ongoing

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1162847 2025-001
    Material Weakness Repeat
  • 1162848 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.872 PUBLIC HOUSING CAPITAL FUND $7.29M
14.850 PUBLIC HOUSING OPERATING FUND $3.78M
14.267 CONTINUUM OF CARE PROGRAM $1.61M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $736,786
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $269,841
14.249 SECTION 8 MODERATE REHABILITATION SINGLE ROOM OCCUPANCY $89,919