Finding 1167536 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2025-12-31

AI Summary

  • Core Issue: The Authority failed to complete annual recertifications as required by HUD regulations, leading to missing documentation for tenant eligibility and rent calculations.
  • Impacted Requirements: Compliance with HUD regulations (24 CFR §§ 982.516, 982.158, and 982.305) and the Authority’s Administrative Plan regarding tenant file completeness.
  • Recommended Follow-up: Improve management oversight and quality control in the recertification process to ensure timely completion and proper documentation retention.

Finding Text

ALN #14.871 Compliance Requirement: Eligibililty Type of Finding: Noncompliance, Significant Deficiency Condition: The Authority did not complete annual recertifications in accordance with HUD regulations and its Administrative Plan, resulting in incomplete or missing documentation necessary to support tenant eligibility and rent determinations. Criteria HUD regulations require public housing authorities to reexamine family income and composition at least once every twelve (12) months and to calculate tenant rent and housing assistance payments based on complete and accurate information (24 CFR §§ 982.516, 982.158, and 982.305). The Authority’s Administrative Plan further establishes requirements for maintaining complete tenant files, including documentation supporting income verification, rent reasonableness, utility allowances, and participant eligibility. Cause The cause of the condition was inadequate management oversight and quality control over the recertification process, resulting in required documentation not being obtained, reviewed, or retained in accordance with established policies and HUD requirements. Effect Failure to properly complete annual recertifications and maintain required supporting documentation increases the risk that tenant rent and housing assistance payments are calculated inaccurately and that ineligible households receive housing assistance. Additionally, incomplete files limit the Authority’s ability to demonstrate compliance with HUD regulations and its Administrative Plan. Questioned Costs No questioned costs were identified; however, unsupported payments were noted due to incomplete eligibility documentation. Context During audit fieldwork, sixty (60) HAP contract files were selected and examined for compliance with annual recertification requirements. Our testing identified pervasive instances of incomplete recertification documentation within the files reviewed. Recommendation The Authority should strengthen oversight and quality control procedures over the Housing Choice Voucher recertification process to ensure that annual recertifications are completed timely and that all required documentation is obtained, reviewed, and retained in accordance with HUD regulations and the Authority’s Administrative Plan.

Corrective Action Plan

Program: Housing Choice Voucher (HCV) Program Finding No. 2024-001 Housing Choice Voucher & Emergency Choice Voucher, ALN #14.871 Compliance Requirement: Eligibility Type of Finding: Noncompliance, Significant Deficiency Corrective Action Overview The Authority acknowledges the finding and agrees that improvements are necessary to strengthen oversight and quality control of the annual recertification process. The Authority is committed to ensuring full compliance with HUD regulations and its Administrative Plan by implementing enhanced procedures, staff training, supervisory review, and ongoing monitoring. ________________________________________ Corrective Actions 1. Standardization of Recertification Process The Authority will update and standardize its annual recertification procedures to ensure that all required steps and documentation are completed consistently and in accordance with HUD regulations and the Administrative Plan. This will include the use of a standardized recertification checklist for each household file to verify that all required income verifications, third-party documentation, rent calculations, utility allowances, and eligibility determinations are obtained and retained. 2. Enhanced Supervisory Review and Quality Control The HCV Program Manager or designated supervisor will conduct a mandatory secondary review of all annual recertifications prior to final approval. This review will confirm that required documentation is complete, accurate, and properly filed before Housing Assistance Payments (HAP) amounts are finalized. Supervisory review will be documented and retained in the tenant file. 3. File Remediation and Backlog Review The Authority will conduct a comprehensive review of all active HCV participant files to identify missing or incomplete annual recertification documentation. Where deficiencies are identified, staff will obtain missing documentation and correct tenant rent and HAP calculations, as necessary. Any discrepancies identified during this review will be documented and resolved in accordance with HUD guidance. 4. Staff Training and Technical Assistance All HCV staff involved in the recertification process will receive refresher training on HUD annual recertification requirements, file documentation standards, and Administrative Plan provisions. Training will emphasize income verification requirements, timeliness standards, and proper file maintenance. Training completion will be documented and retained for monitoring purposes. 5. Ongoing Monitoring and Internal Audits The Authority will implement periodic internal file reviews, including quarterly quality control sampling of HCV recertification files, to ensure continued compliance. Results of internal reviews will be documented, deficiencies will be addressed promptly, and corrective actions will be tracked to completion. ________________________________________ Responsible Staff • Executive Director: Oversight and accountability • HCV Program Manager: Implementation of corrective actions and supervision • HCV Specialists: Completion of recertifications and file documentation • Quality Control Reviewer (or Designee): Ongoing monitoring and file reviews ________________________________________ Implementation Timeline • Within 30 days: o Implement standardized recertification checklist o Begin supervisory review of all annual recertifications • Within 60 days: o Complete staff refresher training o Begin file remediation review of active HCV participant files • Within 90 days: o Complete file remediation o Implement quarterly internal quality control reviews Expected Outcome Implementation of these corrective actions will ensure that annual recertifications are completed timely and accurately, required documentation is properly maintained, and tenant rent and HAP determinations are fully supported. These measures will strengthen internal controls, reduce compliance risk, and improve the Authority’s ability to demonstrate adherence to HUD regulations and its Administrative Plan.

Categories

HUD Housing Programs Eligibility

Other Findings in this Audit

  • 1167535 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.872 PUBLIC HOUSING CAPITAL FUND $2.01M
14.850 PUBLIC AND INDIAN HOUSING $1.66M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $188,308
14.877 PUBLIC HOUSING FAMILY SELF-SUFFICIENCY UNDER RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES $104,999