Finding 1175937 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-02

AI Summary

  • Core Issue: 13.5% of tenant files reviewed were noncompliant, with issues like income miscalculations and missing documentation.
  • Impacted Requirements: Compliance with HUD regulations and internal policies regarding tenant file management is at risk, affecting subsidy determinations.
  • Recommended Follow-Up: Strengthen internal controls and quality procedures, and provide regular training for staff on compliance requirements.

Finding Text

Finding 2025-001 – Moving To Work Demonstration Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Moving To Work Demonstration - subsidy ALN #14.881 Condition & Cause: Our review of one hundred seventy-one (171) Moving To Work tenant files found that twenty-three (23) files were noncompliant, representing 13.5% of our sample. Some files had multiple compliance issues. Specifically, we identified: • Eight (8) files with miscalculations of annual income • Two (2) files missing proper verification of income or deductions • Eleven (11) files missing the EIV report. • Four (4) files missing support for a unit inspection. • Three (3) files for which the annual reexamination was completed late. Using extrapolation, we concluded that the potential misstatement of subsidy from income miscalculations is $35,824, which is immaterial to the financial statements. The majority of the noncompliance occurred within the Low-Rent and Business Activities programs. Contributing factors included high staff turnover and inadequate oversight during the year. As a corrective measure, the Agency established new positions within the department during the fiscal year—including a director and an inspector—to strengthen oversight and improve compliance. Criteria: Compliance requirements are outlined in the Code of Federal Regulations, the Housing Authority’s Admissions and Continued Occupancy Policy (ACOP), Administrative Plan, Moving To Work (MTW) Plan, and specific HUD guidelines for documenting and maintaining Public Housing and Housing Choice Voucher tenant files. Effect: Failure to accurately calculate tenant income, obtain required verification, and conduct timely reexaminations may result in improper subsidy determinations, noncompliance with HUD regulations, and potential financial exposure. Additionally, missing EIV reports and inspection documentation reduce the Agency’s ability to ensure program integrity and housing quality standards. Ongoing noncompliance may also draw scrutiny from regulatory bodies. Recommendation: We recommend that the Agency enhance its internal controls over tenant files by strengthening standardized quality control procedures and support for supervisory oversight. Additionally, staff should receive regular training on HUD compliance requirements. Questioned Costs: $35,824 Repeat Finding: Yes Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

Finding 2025-001 – Moving To Work Demonstration Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Condition & Cause: The review of one hundred seventy-one (171) Moving To Work tenant files found that twenty-three (23) files were noncompliant, representing 13.5% of our sample. Some files had multiple compliance issues. Findings: Income Miscalculations (8)/Missing Income and Deduction Verifications (2)/Missing EIV Reports (11) Corrective Action Plan: The first step in our corrective action plan is to increase staff training. In the past year we have had significant staff turnover at the Management Specialist position. The position responsible for the annual recertification process and rent calculations. We will establish a training curriculum that will provide initial and ongoing training for this position. The goal being to develop and continue to build the knowledge base of the specialist. Ensuring they are able to perform the functions of their job in a manner that is compliant and consistent with HUD and LHA regulations and policies. The second step in our corrective action plan is to improve our compliance monitoring process. This process consists of layers of compliance monitoring that will provide a 100% audit of all files within the calendar year. The structure for compliance monitoring will be as follows: • Peer Review- Another specialist in the office must review and sign off on the completed certification before it is processed electronically. • Management review-The Housing Manager will audit ten files per week in the office including all new move-in files. • Compliance review-The Compliance Coordinator will audit 40 files per week (ten files from each team) and also review all new move-in files at the end of each month. The compliance monitoring will include a review sheet that lists any issues found in the file and a deadline for the team to make the necessary corrections and resubmit the file to compliance. These measures will ensure that all tenant files are reviewed multiple times on an annual basis for compliance, while providing staff training and awareness by identifying issues and correcting them. In addition to training, the Director of Housing Operations will also develop a checklist that will be included with every recertification to ensure that all forms and verifications including the EIV are in each file. Each specialist will sign the checklist certifying their work. Persons Responsible: Director of Housing Operations - Dana Mason; Compliance Coordinator - Dana Tincher; Housing Managers - Renee Christian, Cathy Hall & Sumaya Rayan; Management Specialists - Virginia Auxier, Marlene Stevenson, Brittany Williamson, Giana Hall, Jennfer Loudermilk, Linda Gates, Tiffany Clark & Sherily Blackburn Anticipated Completion Date: June 30, 2026 Finding: Late Annual Reexaminations (3) Corrective Action Plan: LHA staff have implemented several measures to correct this finding. We have hired additional staff and redistributed units to evenly spread the caseload. In addition to these measures, we also implemented reporting that is more accurate and consistent to ensure recertifications are completed timely. LHA’s Strategic Initiatives and Resident Programs (SIRP) Manager will provide monthly reports on recertification status for each team. This report will show upcoming recertifications due within 120 days and any that are past due for each team. Each manager will ensure that any past due recert is completed immediately. Person Responsible: Director of Housing Operations - Dana Mason; Strategic Initiatives and Resident Programs Manager - Samantha Passalacqua; Housing Managers - Renee Christian, Cathy Hall & Sumaya Rayan Anticipated Completion Date: June 30, 2026 Finding: Files Missing support for unit inspections (4) Corrective Action Plan: LHA created a new position earlier this year to address this audit finding. In May the new Public Housing Inspector was hired to conduct annual unit inspections for all LHA owned units. The inspector will complete an NSPIRE inspection in all units independent from the management office. This will ensure that all of the units have annual inspection going forward. The inspection will be maintained electronically for easy access and storage. Person Responsible: Director of Housing Operations - Dana Mason; Compliance Coordinator - Dana Tincher; Public Housing Inspector - Alan Pike Anticipated Completion Date: June 30, 2026

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1175936 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 MOVING TO WORK DEMONSTRATION PROGRAM $33.25M
14.879 MAINSTREAM VOUCHERS $1.72M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $828,918
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $215,749
14.238 SHELTER PLUS CARE $212,785
14.267 CONTINUUM OF CARE PROGRAM $80,095