Finding Text
HQS Annual and Failed Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA901; 2024-2025 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must inspect the unit leased to a family in accordance with it’s Administrative Plan to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Per the Authority's Administrative Plan, all units must pass an HQS inspection prior to the approval of a lease and at least once every 12 months (annually) during the term of the contract, and at other times as needed, to determine that the unit meets HQS. Additionally, per the Authority’s Administrative Plan, both the family and the owner must be given reasonable notice for all inspections. For units under HAP contract that fail to meet HQS, if the reported deficiency is life-threatening, the PHA must, within 24 hours of notification, both inspect the housing unit and notify the owner if the life-threatening deficiency is confirmed. The owner must then make the repairs within 24 hours of PHA notification. If the reported deficiency is non-life-threatening, the PHA must, within 15 days of notification, both inspect the unit and notify the owner if the deficiency is confirmed. The owner must then make the repairs within 30 days of notification from the PHA or within any PHA-approved extension. (24 CFR section 982.405(d)). If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition/Context: During our testing of 60 tenant files for HQS annual inspection requirements, we noted the following in 11 files: - 11 of 60 files tested included units where inspections were not performed annually in accordance with the administrative plan. During our testing of 60 tenant files for HQS failed inspections, we noted the following in 12 files: - 12 of 60 files tested had a reinspection that was not performed timely (30 days or 24 hours, depending on the cited deficiency). - 8 of 60 files tested where the Authority failed to process abatement of units after the second failed inspection. - 2 of 60 files tested where the Authority failed to enforce family obligations for tenant responsible failures. Questioned costs: $15,129 Cause: During the audit period, inspection scheduling, reinspection follow-up, and abatement processing were managed across multiple LHAs with differing capacity levels and geographic challenges, particularly in rural service areas. Oversight relied on decentralized systems and local workflows, which affected the consistency of inspection tracking, timeliness, and enforcement actions. In response, Virginia Housing launched a new statewide inspection model on April 1, 2025, which includes engagement of a third-party inspection vendor and strengthened centralized oversight. This new model is intended to improve inspection scheduling consistency, reinspection timeliness, and enforcement of abatement requirements. Since implementation, the Authority has begun to observe improved coordination and monitoring of inspection activities. However, because the new model was implemented near the end of the audit period, enhancements were not fully reflected in the files selected for testing. Virginia Housing will continue to monitor performance metrics and evaluate the effectiveness of this revised inspection framework to ensure sustained compliance and improved outcomes. Effect: The lack of internal controls in place over the HQS requirements could result in program participants living in unsafe housing, as well as housing assistance payments being paid for units that are not in compliance with HQS requirements. Repeat Finding: This finding is a repeat finding in the immediate prior year. Prior year finding numbers were 2024-003 and 2023-003. Recommendation: We recommend that the Authority reviews its Agent’s processes related to annual and failed HQS inspections to ensure that inspections are completed in a timely manner and in compliance with HUD and the Authority’s requirements. We further recommend that the Authority review its Agent’s procedures to ensure appropriate follow-up is performed to confirm that tenants or landlords make required corrections timely, or that housing assistance payments (HAP) are properly abated for the unit until such corrections are made. We recommend the Authority work with its Agent’s to alleviate any inspector shortage. Views of responsible officials: There is no disagreement with the audit finding.