Finding 1206354 (2023-005)

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

AI Summary

  • Core Issue: The Authority has significant deficiencies in tenant file management, leading to noncompliance with HUD requirements.
  • Impacted Requirements: Internal controls for timely, complete, and accurate tenant files as per ACOP and 24 CFR 960.259 are not being followed.
  • Recommended Follow-Up: The Authority should reassess procedures, address identified deficiencies, and evaluate the impact on the entire tenant population.

Finding Text

Eligibility Public and Indian Housing - ALN 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 2,150 tenants from the Public and Indian Housing program, we tested 43 tenants and the following deficiencies were noted: • 16 files were missing a flat rent option form, • 14 files were missing 214 forms, • 10 units did not have the required inspection performed, • 9 files had incorrect income or missing income support, • 8 files incorrectly contained prior year information in the current year recertification, • 6 files were missing valid 9886 forms, • 2 files were missing identification for adults in the household, and • 1 file was missing birth certificate or other documentation for minors receiving income credits. Criteria: The Authority’s ACOP and 24 CFR 960.259 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 the 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 and retention of required HUD documentation to verify eligibility and calculate accurate tenant rental 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 P ublic and Indian Housing - ALN 14.850 Material Weakness in Internal Controls Material Noncompliance Condition: Out of an approximate population of 2,150 tenants from the Public and Indian Housing program, we tested 43 tenants and the following deficiencies were noted: • 16 files were missing a flat rent option form, • 14 files were missing 214 forms, • 10 units did not have the required inspection performed, • 9 files had incorrect income or missing income support, • 8 files incorrectly contained prior year information in the current year recertification, • 6 files were missing valid 9886 forms, • 2 files were missing identification for adults in the household, and • 1 file was missing birth certificate or other documentation for minors receiving income credits. 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: HACM's Lease and Compliance department has done additional training with their staff since 2023 on Occupancy, Eligibility, Income and Rent Calculation. In addition, the Director has provided additional onboarding training to new employees and has provided YARDI Aspire training in how to perform certain eligibility tasks in YARDI. We believe that the error rate will decrease in future years from 2023. In add ition,between March 2026 and June 2026, the Lease and Compliance Director will work with all staff that perform initial eligibility or recertifications to reiterate the major topics that HACM has had deficiencies and the proper way to treat those items. Name of Responsible Person: Marquetta Treadway, Lease and Compliance Director Projected Completion Date: June 30, 2026

Categories

HUD Housing Programs Eligibility Material Weakness

Other Findings in this Audit

  • 1206348 2023-002
    Material Weakness Repeat
  • 1206349 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
  • 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