Finding 1206349 (2023-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2026-04-10

AI Summary

  • Core Issue: There are significant deficiencies in tenant file management for the Housing Voucher Cluster, including missing documents and late recertifications.
  • Impacted Requirements: Compliance with HUD regulations and the Authority’s Administrative Plan is not being met, risking incorrect rental assistance amounts.
  • Recommended Follow-Up: The Authority should improve internal controls, address the identified deficiencies, and assess the impact on all tenant files beyond the sample tested.

Finding Text

Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance (Repeated in part from prior year, Finding No. 2022-003 and 2022-004) Condition: Out of an approximate population of 5,800 Housing Voucher Cluster tenants we tested 41 tenants and the following deficiencies were noted: • 10 files were missing 214 forms, • 9 files had incorrect income or missing income support, • 9 files were missing identification for adults in the household, • 8 files were missing birth certificates or other support for minors receiving income credits, • 6 units did not have the required inspections performed, • 3 files had late recertifications, • 3 files were missing valid 9886 forms, • 1 file was missing support of rent reasonableness that was required to be performed during the year for that unit, • 1 file was missing required asset support, and • 1 file contained an incorrect payment standard. Criteria: The Authority’s Administrative Plan and 24 CFR 982.516 requires internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Context: The auditor haphazardly selected tenant files out of the population from each program as outlined, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges and did not have the available staff to follow the established internal controls to ensure proper compliance with regards to timely recertifications and collection of required HUD documentation to verify eligibility and calculate accurate housing assistance payments. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: Unknown. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: See Corrective Action Plan.

Corrective Action Plan

Eligibility Housing Voucher Cluster Material Weakness in Internal Controls Material Noncompliance Condition: Out of an approximate population of 5,800 Housing Voucher Cluster tenants we tested 41 tenants and the following deficiencies were noted: • 10 files were missing 214 forms, • 9 files had incorrect income or missing income support, • 9 files were missing identification for adults in the household, • 8 files were missing birth certificates or other support for minors receiving income credits, • 6 units did not have the required inspections performed, • 3 files had late recertifications, • 3 files were missing valid 9886 forms, • 1 file was missing support of rent reasonableness that was required to be performed d uring the year for that unit, • 1 file was missing required asset support, and • I file contained an incorrect payment standard. A uditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor's sample. Action Taken: Via a nationwide Request for Proposal, HACM hired the contractor, CVR Associates, Inc. (CVR) to manage and operate the entire Housing Choice Voucher program for HACM, effective January 2, 2025. This contract is currently overseen by the Acting Secretary-Executive Director and will be overseen by the Chief Operations Officer once a new one is hired. CVR was selected as the contractor in part due to their extensive experience in managing similar voucher programs nationwide and on their tools/software that they have developed to manage items, such as quality control testing in the areas such as the items noted above. CVR provided additional training to staff, prepared new standard operating procedures, a nd perform quality control testing over the course of the entire year. Many of the SEMAP indicators have improved, but some have additional improvement still needed based on the 2025 SEMAP results. When there are issues, the CVR Quality Control team follows up with the staff person to correct the issue, and to provide guidance or additional training with the goal to reduce the error rate in the future. We believe that HACM will be back to being a standard performer or higher in 2026 in general for SEMAP Name of Responsible Person: Ken Barbeau, Acting Secretary-Executive Director; Chief Operations Officer (once hired); Projected Completion Date: December 31, 2026

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1206348 2023-002
    Material Weakness Repeat
  • 1206350 2023-003
    Material Weakness Repeat
  • 1206351 2023-003
    Material Weakness Repeat
  • 1206352 2023-004
    Material Weakness Repeat
  • 1206353 2023-004
    Material Weakness Repeat
  • 1206354 2023-005
    Material Weakness Repeat
  • 1206355 2023-006
    Material Weakness Repeat
  • 1206356 2023-007
    Material Weakness Repeat
  • 1206357 2023-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $7.60M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $4.69M
14.872 PUBLIC HOUSING CAPITAL FUND $3.34M
14.895 JOBS-PLUS PILOT INITIATIVE $1.64M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $946,780
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $89,889
14.889 CHOICE NEIGHBORHOODS IMPLEMENTATION GRANTS $48,677
14.249 SECTION 8 MODERATE REHABILITATION SINGLE ROOM OCCUPANCY $23,232