Finding 1208841 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-04-27
Audit: 399753
Organization: Fremont Housing Agency (NE)

AI Summary

  • Core Issue: The Housing Authority failed to implement HOTMA provisions for the Housing Choice Voucher program by the July 1, 2025 deadline.
  • Impacted Requirements: This noncompliance risks the program's adherence to HUD regulations during the period from July 1, 2025, to September 2025.
  • Recommended Follow-up: The Housing Authority should monitor HUD updates and establish procedures for timely adoption of future requirements, ensuring policies are reviewed before deadlines.

Finding Text

Finding 2025-002: HOTMA Housing Choice Voucher – 14.871 Material Weakness/Noncompliance – Eligibility Criteria: The Housing Opportunity Through Modernization Act of 2016 (HOTMA), as implemented through HUD regulations and guidance, required public housing agencies administering the Housing Choice Voucher (HCV) program to adopt and implement certain HOTMA provisions no later than July 1, 2025. Public housing agencies are responsible for ensuring program policies, procedures, and operations are updated timely to comply with HUD requirements. Condition: The Housing Authority did not implement the required HOTMA provisions applicable to the Housing Choice Voucher program by the required effective date of July 1, 2025. As a result, the Authority administered the Housing Choice Voucher program for approximately two months without full compliance with HUD’s HOTMA implementation requirements. Cause: The Authority did not have adequate internal controls in place to ensure timely adoption and implementation of new HUD regulatory requirements and management was under the impression these requirements had been delayed. Effect or Potential Effect: Failure to timely implement HOTMA requirements increases the risk that the Housing Choice Voucher program was not administered in full compliance with HUD regulations during the period from July 1, 2025 through September 2025. It should be noted we noted no instance of noncompliance as a result of this failure during our testing. Recommendation: We recommend that the Housing Authority continue to monitor HUD regulatory updates and establish procedures to ensure timely adoption and implementation of future program requirements. Management should also ensure that updated policies and procedures are reviewed and approved prior to required effective dates to maintain compliance with HUD and Uniform Guidance requirements. View of the Responsible Officials of the Auditee: The auditee’s management agrees with the finding.

Corrective Action Plan

The Fremont Housing Authority contracted with Nan McKay Consulting to create a draft of the ACOP and Administrative Plan incorporating HOTMA requirements. Due to multiple delays in HOTMA’s implementation by HUD, the provisions were not required until July 1, 2025. To ensure timely compliance in the future, the Agency has established internal procedures to track HUD regulatory updates, assign responsibilities for updating policies, and review all revisions prior to their required effective dates. This process, combined with the ongoing Nan McKay subscription for monitoring and guidance, will ensure that all future regulatory changes are incorporated and approved in a timely manner.

Categories

HUD Housing Programs

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $1.09M
14.872 PUBLIC HOUSING CAPITAL FUND $650,112
14.850 PUBLIC HOUSING OPERATING FUND $469,428
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $97,115