Finding 1172084 (2024-004)

Material Weakness Repeat Finding
Requirement
ABE
Questioned Costs
-
Year
2024
Accepted
2026-02-03

AI Summary

  • Core Issue: Significant deficiencies were found in tenant files, including missing documentation and incorrect information, indicating non-compliance with HUD requirements.
  • Impacted Requirements: Internal controls outlined in the Authority’s Administrative Plan and 24 CFR 982.516 were not effectively implemented, leading to issues with timely recertifications and eligibility verification.
  • Recommended Follow-Up: The Authority should reassess and strengthen procedures to ensure compliance, address the noted deficiencies, and evaluate the potential impact on the entire tenant population.

Finding Text

Condition: Out of an approximate population of 375 Housing Voucher Cluster tenants we selected 40 tenants for testing and the following deficiencies were noted: • 5 files were not able to be provided for testing, • 15 files were missing 214 forms, • 13 files had incorrect income or missing income support, • 13 files contained incorrect or unsupported utility allowance, • 12 files were missing support of rent reasonableness that was required to be performed during the year for that unit, • 11 files were not able to support the amount paid to landlords on the HAP register, • 9 files were missing valid 9886 forms, • 8 files contained an incorrect payment standard, • 7 files did not have the required inspections performed, • 6 files were missing identification for adults in the household, • 4 files were not able to provide a prior year 50058 form to determine if the current year recertification occurred within the 12 month period, and • 1 file contained an incomplete 50058 form to determine the amount of HAP calculated. Context: The auditor haphazardly selected tenant files out of the population from each program as outlined, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Criteria: The Authority’s Administrative Plan and 24 CFR 982.516 requires internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges and did not have the available staff to follow the established internal controls to ensure proper compliance with regards to timely recertifications and collection of required HUD documentation to verify eligibility and calculate accurate housing assistance payments. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: Unknown. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: See Corrective Action Plan.

Corrective Action Plan

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in allowability and eligibility. We accept responsibility for the deficiencies in internal control over allowability and eligibility and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Immediate File Correction & Review: Correct all identified deficiencies in the sampled files. Furthermore, a 100% review of the remaining -335 files must be conducted to identify if these errors are systematic [1.1]. • Repayment and Re-calculation: For files with incorrect income, utility allowance, or payment standards, the Authority must recalculate the Housing Assistance Payments (HAP) and determine if repayments to HUD are necessary. • Strengthen Internal Controls: • Implement a File Checklist: Require a mandatory, signed checklist for all new admissions and annual recertifications to ensure all 214 forms, 9886 forms, income verifications, and ID documentation are present. • Supervisory Review: Implement a mandatory, independent supervisory review of a percentage of files before HAP payments are authorized. • Inspection Tracking System: Utilize automated tools to track HQS inspection dates to prevent late or missed inspections. • Training: Provide staff training on HUD eligibility, income verification, and rent calculation procedures, specifically focusing on the requirements in 24 CFR Part 5. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by June 1, 2026.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1172072 2024-002
    Material Weakness Repeat
  • 1172073 2024-003
    Material Weakness Repeat
  • 1172074 2024-004
    Material Weakness Repeat
  • 1172075 2024-005
    Material Weakness Repeat
  • 1172076 2024-006
    Material Weakness Repeat
  • 1172077 2024-002
    Material Weakness Repeat
  • 1172078 2024-003
    Material Weakness Repeat
  • 1172079 2024-004
    Material Weakness Repeat
  • 1172080 2024-005
    Material Weakness Repeat
  • 1172081 2024-006
    Material Weakness Repeat
  • 1172082 2024-002
    Material Weakness Repeat
  • 1172083 2024-003
    Material Weakness Repeat
  • 1172085 2024-005
    Material Weakness Repeat
  • 1172086 2024-006
    Material Weakness Repeat
  • 1172087 2024-002
    Material Weakness Repeat
  • 1172088 2024-003
    Material Weakness Repeat
  • 1172089 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.872 PUBLIC HOUSING CAPITAL FUND $847,209
14.850 PUBLIC HOUSING OPERATING FUND $533,477
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $270,152
14.879 MAINSTREAM VOUCHERS $252,031