Finding 1169877 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-21
Audit: 383033
Organization: City of Concord (NC)

AI Summary

  • Core Issue: The City failed to enforce Housing Quality Standards (HQS) corrections, allowing owners to receive benefits despite deficiencies.
  • Impacted Requirements: Non-compliance with 24 CFR sections 982.158(d) and 982.404 regarding timely correction of HQS deficiencies.
  • Recommended Follow-Up: Management should establish and enforce controls to ensure timely HQS enforcement and prevent future non-compliance.

Finding Text

Material Non‐Compliance Material Weakness, Special Tests and Provisions Criteria: In accordance with 24 CFR sections 982.158(d) and 982.404, units under housing assistance payment (HAP) contract that fail to meet Housing Quality Standards (HQS), the Public Housing Authority (PHA) must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. Condition: The City did not follow procedures to ensure that the HQS were corrected or subsequent procedures to stop HAP were not enforced. Context: Of the 293 failed inspections during the current year, we examined 60 and determined that 20 (34% valued at $66,952) failed inspections were not corrected or the HAP were not stopped timely. Effect: Owner could receive benefits for which they are not eligible Cause: Lack of proper internal control over HQS enforcement Identification of a Repeat Finding: This is modified and a repeat of Finding 2024-002 from the immediate previous audit. Questioned Cost: In accordance with 2 CFR 200, auditors are required to report known questioned costs when likely questioned costs are greater than $25,000. The sample results identified $66,952 in known questioned costs. Recommendation: Management should implement controls to ensure that HQS enforcement procedures are followed timely. Views of Responsible Officials and Planned Corrective Actions: The City agrees with this finding. Please refer to the Corrective Action Plan section of this report.

Corrective Action Plan

Ensure compliance with Housing Quality Standards (HQS) and enforce owner accountability: 1. Staff Training: Retrain inspection and program staff on HQS enforcement protocols under 24 CFR §982.404(a)(3), as well as Admin Plan specific timeframes and escalation procedures when HQS deficiencies are not corrected within the required 24-hour (life-threatening) or 30-day (non-life-threatening) periods. 2. Monitoring: Establish a monthly compliance report that is presented by the Inspections Coordinator reviewed by management to ensure HAP payments are stopped timely for noncompliant units. Work to move all reporting to electronic files which will provide time and date stamps. 3. Landlord Communication: Issue updated landlord written notices outlining enforcement expectations and consequences for noncompliance. Make the Admin Plan publicly accessible to allow tenants and landlords to reference specific timeframes based on deficiencies. 4. Begin a Landlord Training: Staff to work to create a yearly or bi-yearly landlord training to review issues, expectations, processes, and timeframe associated with HCV program. Also gives landlord’s the opportunity to provide feedback for staff which may help address shortfalls.

Categories

HUD Housing Programs Special Tests & Provisions

Other Findings in this Audit

  • 1169876 2025-001
    Material Weakness Repeat
  • 1169878 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.507 FEDERAL TRANSIT FORMULA GRANTS $4.02M
14.850 PUBLIC HOUSING OPERATING FUND $1.10M
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $1.02M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $366,272
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $271,582
15.916 OUTDOOR RECREATION ACQUISITION, DEVELOPMENT AND PLANNING $257,914
20.526 BUSES AND BUS FACILITIES FORMULA, COMPETITIVE, AND LOW OR NO EMISSIONS PROGRAMS $239,588
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $181,782
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $177,773
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $150,822
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $121,337
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $94,782
97.137 STATE AND LOCAL CYBERSECURITY GRANT PROGRAM TRIBAL CYBERSECURITY GRANT PROGRAM $62,180
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $49,819
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $46,740
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $34,733
14.872 PUBLIC HOUSING CAPITAL FUND $27,875
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $22,066
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $14,524
16.922 EQUITABLE SHARING PROGRAM $10,000
20.205 HIGHWAY PLANNING AND CONSTRUCTION $8,900
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $3,306