Finding 1176415 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-04

AI Summary

  • Core Issue: The Commission failed to consistently meet eligibility requirements for the Section 8 program, leading to a significant deficiency in internal controls.
  • Impacted Requirements: Eligibility determination processes, including documentation of income, assets, and tenant certifications, were not properly followed, resulting in questioned costs of $13,635.
  • Recommended Follow-Up: Implement stronger processes to ensure all necessary documentation is maintained during client recertification to comply with HUD requirements.

Finding Text

PBRA/MOD Eligibility 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 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/24-6/30/25) Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance. - Other Matters Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not consistently use internal controls to ensure that eligibility requirements were being met. Questioned Costs: $ 13,635 Context: Testing of 60 tenant files for eligibility revealed that 1 file had the following exception: - 1 file that was missing support needed to substantiate the asset total per HUD-50058/HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

PBRA/MOD Eligibility Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, will retrain all site staff on acceptable and complete forms of income, asset, and expense documentation for initial certifications and the annual recertification process no later than February 15, 2026. Pratum's Compliance team will continue to review each new move-in file from eligibility determination through lease execution to ensure ongoing programmatic compliance. In addition, the Compliance team will complete supplemental training by February 15, 2026, to reinforce proper use of the internal control's checklist, which is required to be attached to all submitted move-in files. Name(s) of the contact person(s) responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action outlined above.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1176411 2025-001
    Material Weakness Repeat
  • 1176412 2025-001
    Material Weakness Repeat
  • 1176413 2025-001
    Material Weakness Repeat
  • 1176414 2025-002
    Material Weakness Repeat
  • 1176416 2025-003
    Material Weakness Repeat
  • 1176417 2025-003
    Material Weakness Repeat
  • 1176418 2025-004
    Material Weakness Repeat
  • 1176419 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.188 HOUSING FINANCE AGENCIES (HFA) RISK SHARING $311.02M
14.267 CONTINUUM OF CARE PROGRAM $4.97M
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $3.37M
14.879 MAINSTREAM VOUCHERS $2.33M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $1.98M
93.086 HEALTHY MARRIAGE PROMOTION AND RESPONSIBLE FATHERHOOD GRANTS $719,073
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $604,446
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $526,862
14.269 HURRICANE SANDY COMMUNITY DEVELOPMENT BLOCK GRANT DISASTER RECOVERY GRANTS (CDBG-DR) $261,312
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $50,214