Finding 1172804 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-09
Audit: 386135

AI Summary

  • Core Issue: There is a significant deficiency in enforcing Housing Quality Standards (HQS) for the Housing Choice Vouchers Program, with all 25 inspected cases showing non-compliance.
  • Impacted Requirements: HUD mandates timely re-inspections and proper documentation of failed inspections, which are currently lacking.
  • Recommended Follow-Up: Implement stricter monitoring procedures, enhance staff training, and conduct regular audits to ensure compliance and address lapses promptly.

Finding Text

Program Name Housing Choice Vouchers "Internal Control" Significant Deficiency N Special Tests ALN(s) 14.871 2025-001 HQS Enforcement Criteria HUD requires that all units under the Housing Choice Vouchers Program meet specific Housing Quality Standards (HQS). In cases of failed inspections, timely re-inspections are mandatory, and if compliance is not achieved, abatement of Housing Assistance Payments (HAP) or voucher cancellation is required. Condition We selected 25 failed HQS inspections from the Authority's database. During testing management was unable to provide the initial failed inspection forms with deficiencies notate. During discussion with Sec 8 director, we determined that the inspection forms are not printed and maintained. On the form, there is not sufficient documentation of failed items and the passing inspection forms have the date of the initial failed inspection but not the actual passing date. Other control issues include lack of follow-up on failed units and abatement of HAP after allowable period. Context This finding represents a potentially systemic issue within the Housing Voucher Cluster program, as it was identified in all 25 files tested out of a sample of 25 cases. It highlights a need for more rigorous enforcement and monitoring of HQS compliance. Cause The non-compliance appears to stem from oversight or procedural lapses in the enforcement of HQS within the Housing Voucher Cluster program. This may be due to inadequate training, monitoring, or failure to adhere to established protocols. Effect This non-compliance undermines the integrity of the Housing Choice Vouchers Program and may lead to tenants living in substandard conditions. It also represents a risk of improper use of federal funds and can impact the credibility and effectiveness of the program. Recommendations Implement more stringent procedures for monitoring HQS compliance, including timely reinspection and enforcement of HAP abatement or voucher cancellation. Enhance training for staff involved in the HQS process to ensure a thorough understanding of compliance requirements. Establish a system of regular audits to identify and rectify lapses in HQS enforcement promptly. Questioned Costs The exact monetary impact needs further investigation to determine the amount of HAP that should have been abated for the period of non-compliance. Management Views The auditee acknowledges the deficiency in enforcing Housing Quality Standards (HQS) as highlighted in the finding. In response to this issue, the management commits to implementing a comprehensive Corrective Action Plan.

Corrective Action Plan

The non-compliance resulted primarily from operational and system limitations rather than the absence of policy or guidance. The PHA had inspection procedures and documentation expectations in place and communicated to inspection staff; however, the inspection software that we use, Tenmast, currently does not adequately support printing, retention, tracking and follow-up of former HQS inspection documentation and present NSPIRE documentation, reinspection deadlines or enforcement actions. As HUD oversight expectations increased and NSPIRE requirements were implemented, reliance on manual tracking and workarounds created a risk of incomplete documentation and delayed follow-up. While inspections were conducted as required, system constraints limited the PHA's ability to consistently document failed items, record actual passing dates and initiate timely enforcement actions, including HAP abatement. To further strengthen compliance and address these risks, the PHA updated its Administrative Plan effective July 1, 2025, to more clearly define NSPIRE compliance standards, documentation requirements, reinspection timelines, enforcement procedures and abatement actions. STEPS TO IMPROVE: 1. Reinforce NSPIRE inspection procedures previously issued to inspectors, including documentation, notification, reinspection and enforcement requirements. 2. Implement refresher training for inspection staff to ensure consistent application of HUD and PHA NSPIRE policies, including life-threatening and non-life-threatening deficiencies. 3. Require retention of complete HUD-52580 inspection reports for all failed and passed inspections, including accurate documentation of deficiency correction dates. 4. 4. Strengthen review of inspection files to ensure timely follow-up, reinspection scheduling and enforcement actions by the Section 8 Director. 5. Transition inspection tracking and compliance enforcement from our current software company, Ten mast, to a new software company, Yardi, to improve system controls, documentation retention and monitoring capabilities. This implementation should occur in 2026. 6. Apply the updated Administrative Plan effective July 1, 2025, to ensure consistent enforcement of HAP abatement and contract termination requirements. Effective December 1, 2024, the PHA began utilizing NSPIRE to support a more modernized inspection system. Existing landlords were formally notified of the new inspection and enforcement requirements on September 1, 2024. The Section 8 Director will conduct periodic supervisory file reviews to verify that inspection notices, HUD- 52580 reports, reinspection documentation and enforcement actions are properly maintained and timely. The PHA is currently in the process of implementing Yardi as its primary inspection and case-management system. Once fully operational, Yardi will provide enhanced capabilities for tracking failed inspections, monitoring reinspection deadlines, documenting compliance and enforcing HAP abatement in accordance with HUD and NSPIRE requirements. Management will utilize system-generated reports and ongoing internal reviews to identify and promptly address compliance issues. The Section 8 Director acknowledges the deficiencies identified and is committed to strengthening NSPIRE enforcement through improved system controls, clarified policy, staff training and ongoing monitoring. These corrective actions are intended to ensure program integrity, protect tenant safety and maintain compliance with HUD regulations. Additional Remarks: Under our finding, the finding was reported for HOS Enforcement. Our agency changed to the NSPIRE Protocol for inspections as of 12/1/2024. Out of the 25 failed inspections sampled, 7 fell under the previous HQS protocol and the other 18, NSPIRE

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $8.37M
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM $68,361