Finding 1166215 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2025-12-22

AI Summary

  • Core Issue: The PHA failed to maintain complete tenant files, leading to material non-compliance with federal eligibility requirements.
  • Impacted Requirements: Key documents like income verification and authorization forms were missing from tenant files, violating 24 CFR regulations.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all required tenant documentation is collected, maintained, and available for audits.

Finding Text

III. Federal Award Findings and Questioned Costs Finding 2025-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 11,032 units. Of a sample size of sixty-nine (69) tenant files, the following was noted: • Declaration of Section 214 Status form was missing in one (1) file • HUD-9886 Authorization for Release of Information was missing in six (6) files • Lead based paint form was missing in one (1) file • HUD-50058 Form applicable to the audit period was missing in seven (7) files. Our sample size is statistically valid. Known Questioned Costs: $168,325. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. the inspection of the tenant files and will implement internal control procedures that will ensure compliance of federal regulations.

Corrective Action Plan

U.S. Department of Housing and Urban Development: The Housing Authority of the County of Contra Costa respectfully submits the following corrective action plan for the year ended March 31, 2025. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the March 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 11,032 units. Of a sample size of sixty-nine (69) tenant files, the following was noted: - Declaration of Section 214 Status form was missing in one (1) file - HUD-9886 Authorization for Release of Information was missing in six (6) files - Lead based paint form was missing in one (1) file - HUD-50058 Form applicable to the audit period was missing in seven (7) files Our sample size is statistically valid. Known Questioned Costs: $168,325 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement.. Views of responsible officials and planned corrective action: We agree with the Auditor’s observations on the inspection of the tenant files and will implement internal control procedures that will ensure compliance of federal regulations. HACCC identified two primary causes of the deficiency and has outlined corrective measures to address them. Firts, HACCC recognized the need for improved training on supervisory tools used to monitor recertification deadlines. Management was retrained in November 2025 on the use of WorkQueue oversight tools and on conducting daily team stand-up meetings to reinforce production goals. Key performance indicators from these meetings flow to management reports and executive leadership for ongoing monitoring. Second, HACCC'S HCV program partnered with Paul Edwards Management and Consulting (PEM) on May 1, 2024. This partnership provided HACCC's HCV program with technical assistance and coverage of positions which had remained vacant from 2021 until recently. Ingrid Layne, Director of Assistance Housing, will be responsible to implement this corrective action by March 31, 2026.

Categories

HUD Housing Programs Eligibility Material Weakness

Other Findings in this Audit

  • 1166214 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $222.25M
14.850 PUBLIC HOUSING OPERATING FUND $8.25M
14.267 CONTINUUM OF CARE PROGRAM $7.20M
14.879 MAINSTREAM VOUCHERS $4.92M
14.872 PUBLIC HOUSING CAPITAL FUND $4.31M
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $320,812