Finding 1165261 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-18
Audit: 375748
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: The Authority decreased payment standards for tenants without the required 12-month waiting period, leading to premature rent increases.
  • Impacted Requirements: This violates HUD regulations, risking financial hardship for tenants and potential sanctions against the Authority.
  • Recommended Follow-Up: Implement internal controls to ensure compliance and review affected cases for necessary retroactive corrections.

Finding Text

2025-001 – SPECIAL TESTS AND PROVISIONS: PAYMENT STANDARDS Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 / 14.879 – Housing Voucher Cluster CRITERIA Per 24 CFR § 982.503 and HUD Housing Choice Voucher Program guidance, public housing authorities (PHAs) must provide tenants with at least a 12-month waiting period before decreasing payment standards for households currently receiving assistance. The decreased payment standard is to be applied at the family’s next annual reexamination after the waiting period. CONDITION During our testing of the Housing Voucher Cluster, we noted the Authority decreased payment standards. The decreased standards were applied immediately to current tenant rent calculations for 12 files we reviewed, without observing the required 12-month waiting period. Tenants who should have retained the higher payment standard until their next annual reexamination were subject to a reduced subsidy and higher rent share prior to the allowed timeframe. CAUSE The Authority did not have adequate procedures in place to ensure compliance with HUD requirements for implementing decreases in payment standards, resulting in premature application of new standards. EFFECT Tenants’ rent portions increased earlier than allowed, potentially resulting in financial hardship and noncompliance with federal regulations. The Authority is at risk for HUD sanctions and may be required to make retroactive subsidy adjustments. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 40 from a population of 230. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Authority implement internal controls to ensure that any future decrease in payment standards is not applied to current participants until the required waiting period has elapsed. The Authority should review all affected cases and, if necessary, make retroactive corrections to tenant rent calculations and subsidy amounts. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2025-001 – SPECIAL TESTS AND PROVISIONS: PAYMENT STANDARDS Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 / 14.879 – Housing Voucher Cluster Issue Identified: It was brought to the attention of the North Providence Housing Authority (NPHA) in May 2025 that a procedural error occurred regarding the implementation of decreased payment standards for existing subsidized participants. The error involved applying the decreased payment standards immediately (at most recent annual reexamination), rather than adhering to the required 12-month written notice period for existing participants. The correct procedure, as per HUD policy, requires applying the decreased payment standards only at the participant's second annual review of income following the effective date of the decrease. Corrective Action: The NPHA took the following immediate and diligent steps to rectify this oversight: 1. Identification of Affected Participants: A comprehensive review was conducted to accurately identify all families whose subsidies were incorrectly calculated due to the premature application of the decreased payment standards. 2. Recalculation and Adjustment: For all affected participants, the housing assistance payment (HAP) was retroactively recalculated using the higher, correct payment standard that should have remained in effect during the notice period. 3. Issuance of Refunds: The difference between the higher, correct HAP, and the lower, incorrect HAP was calculated. This amount was then refunded to compensate participants for any increased tenant rent they may have paid as a result of the error. Status of Correction: The NPHA confirms that the corrective action is complete. • As of Friday, September 26, 2025, all identified affected participants have been fully compensated and made whole. • The distribution of all calculated refunds related to the incorrect application of the 2024/2025 payment standards is finalized. Preventative Measures: To prevent recurrence, the NPHA has implemented updated policies and procedures to ensure strict compliance with HUD regulations regarding changes to payment standards: • The NPHA staff is now fully aware of the specific HUD policy requiring a 12-month written notice for existing participants before a decreased payment standard is applied. • New internal controls and verification steps have been established to ensure that future decreased payment standards are applied only at the second annual income review for existing participants, following the issuance of the 12-month notice. Planned Implementation Date of Corrective Action: July 1, 2025. Person Responsible for Corrective Action: Marilee Arsenault, Stephnie Dos Reis, and Eileen Reyes

Categories

HUD Housing Programs Special Tests & Provisions

Other Findings in this Audit

  • 1165260 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $3.42M
14.850 PUBLIC HOUSING OPERATING FUND $591,762
14.872 PUBLIC HOUSING CAPITAL FUND $579,678
14.879 MAINSTREAM VOUCHERS $494,540
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $98,615