Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project Based Cluster Assistance Listing Number: 14.195 & 14.856 Award Period: 1/1/2021-12/31/2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: In accordance with 24 CFR section 5.653, applicants for Section 8 Project-Based Assistance must meet all eligibility requirements to receive housing assistance. Additionally, in accordance with 880.603, 881.601, 882.515, 884.218, 886.124, and 886.324, reexaminations of family income and composition must occur on at least an annual basis. 24 CFR sections 880.603, 882.808, 833.701, 884.214, 886.119, and 886.318 state that tenant income and other key values, including medical expenses, need to be verified as part of eligibility determination. Accurate calculations of tenant rent payments must be made, in accordance with 24 CFR section 5.613. Further, tenant utility allowances must be properly applied within tenant rent calculations, in accordance with 24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326. Condition: During our testing, we noted instances where the Authority did not follow the internal controls in place to ensure compliance with eligibility and examination requirements. Questioned Costs: $4,164 Content: A sample of 40 participants were selected for testing out of a total 607 available units. Based on testing of 40 tenant file samples, we observed the following: 1 of 40 items selected could not be tested, as the Authority could not locate the tenant file information. 1 of 40 items selected lacked sufficient backup to support reported medical expenses. As a result, the rent payment was not properly calculated. 1 of 40 items selected did not have a recertification performed annually. Cause: The Authority underwent a major software system conversion during the audit period, and certain tenant file data did not migrate completely or accurately, resulting in missing documentation in a limited number of historical files. At the same time, operations were impacted by COVID-19 public health restrictions, including prolonged remote work and office closure through July 2021, which delayed the receipt and verification of tenant documentation and reexamination processing. These operational disruptions were compounded by significant staff turnover and onboarding of new staff during the pandemic, which reduced capacity to consistently apply internal controls and ensure timely file maintenance and recertification. As a result of these issues, the Authority did not sufficiently monitor controls to ensure proper storage and collection of tenant information and files. Further, staff inexperience and clerical errors caused failures to ensure the tenant information was recorded accurately, and the Authority did not sufficiently monitor controls to ensure all examinations were performed timely. Effect: The Authority is not providing accurate data to HUD to ensure the proper accounting of tenant information and the Authority is not in compliance with HUD regulations. Repeat Finding: No Recommendation: We recommend that management review their procedures for retrieving tenant information and establish a method that ensures compliance. We recommend that the Authority should review their examination policies to ensure that all examinations are performed timely. Views of Responsible Officials: The Authority concurs with this finding. During the period under audit, program administration was affected by both the COVID-19 public health emergency and a software system conversion. The Authority’s administrative offices remained closed to the public through July 2021, and remote work conditions created delays in obtaining and verifying documentation needed for eligibility reviews, medical expense verification, and annual reexaminations. Additionally, during this time, the Authority transitioned to a new housing management software system, and certain tenant file records did not migrate completely, contributing to incomplete documentation within one of the sampled files. These challenges were compounded by staff turnover during the pandemic, which required onboarding and training of new personnel under nonstandard operating conditions. It is important to note that the exceptions identified were limited in scope relative to the total portfolio tested. For 37 of the 40 files reviewed, eligibility determinations, reexamination processing, and rent calculations were completed correctly, indicating that the Authority’s policies and procedures are fundamentally sound; however, execution was impacted during this extraordinary period.