Finding 1211171 (2024-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2026-05-01
Audit: 400373
Organization: Houston Housing Authority (TX)

AI Summary

  • Core Issue: Significant deficiencies in tenant file management for both Section 8 and Low Rent Public Housing programs, leading to noncompliance with HUD requirements.
  • Impacted Requirements: Internal controls for timely recertifications and documentation verification were not followed, violating established guidelines.
  • Recommended Follow-Up: The Authority should review and improve procedures to ensure compliance, address identified deficiencies, and assess the broader impact on all tenant files.

Finding Text

Eligibility Moving to Work Demonstration Program AL No. 14.881 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 17,500 of Section 8 Housing Choice Voucher and 2,200 Low Rent Public Housing tenants the following deficiencies were noted: Section 8 Housing Choice Voucher (a total of 11 tenants selected for testing): • One file did not have annual recertifications performed during the year, • Two files did not have 9886 release of information forms within 15 months of annual recertification, • Three files did not have an annual recertification performed within 12 months of the previous certification, • Two files did not have an utility allowance calculation sheet during annual recertification, • Three files did not have documentation necessary to verify the reported income, • Two files did not have a inspections performed during the period, and • Two files did not utilize the correct payment standard. Eligibility (continued) Moving to Work Demonstration Program AL No. 14.881 Material Weakness in Internal Control Material Noncompliance Low Rent Public Housing (a total of 12 tenants selected for testing): • Three files did not contain flat rent options forms, • Four files did not have documentation necessary to verify the reported income, • Six files did not have a 214 declaration for a member of the household, and • One file did not have support necessary to verify income allowances, Criteria: The Authority’s ACOP, Administrative Plan, 24 CFR 960.259, and 24 CFR 982.516 require 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 randomly 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 during the onset of COVID- 19 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 Moving to Work Demonstration Program AL No. 14.881 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 17,500 of Section 8 Housing Choice Voucher and 2,200 Low Rent Public Housing tenants the following deficiencies were noted: Section 8 Housing Choice Voucher (a total of 11 tenants selected for testing): One file did not have annual recertifications performed during the year, Two files did not have 9886 release of information forms within 15 months of annual recertification, Three files did not have an annual recertification performed with 12 months of the previous certification, Two files did not have a utility allowance calculation sheet during annual recertification, Three files did not have documentation necessary to verify the reported income, Two files did not have an inspection performed during the period, and Two files did not utilize the correct payment standard. Low Rent Public Housing (a total of 12 tenants selected for testing): Three files did not contain flat rent options forms, Four files did not have documentation necessary to verify the reported income, Six files did not have a 214 declaration for a member of the household, and One file did not have support necessary to verify income allowances. 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. Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required that work flows had to be modified. This modification and implementation of a new processing system did not allow staff to conduct the necessary reviews of existing files to make sure that the compliance related materials that should be found in each file were to be completed. This issue has been discussed and there will be an internal review conducted on file samples to determine what compliance deficiencies are prevalent. Corrective action steps will be implemented to address these issues designed to correct them. Additional training resources will be devoted to staff in these departments designed to improve quality control with these program areas. The Senior Vice President of Voucher Operations and the Senior Vice President of Asset Management will be focused on improving the quality of our files that support the voucher and public housing operations.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1211170 2024-001
    Material Weakness Repeat
  • 1211172 2024-003
    Material Weakness Repeat
  • 1211173 2024-001
    Material Weakness Repeat
  • 1211174 2024-003
    Material Weakness Repeat
  • 1211175 2024-001
    Material Weakness Repeat
  • 1211176 2024-001
    Material Weakness Repeat
  • 1211177 2024-004
    Material Weakness Repeat
  • 1211178 2024-001
    Material Weakness Repeat
  • 1211179 2024-004
    Material Weakness Repeat
  • 1211180 2024-004
    Material Weakness Repeat
  • 1211181 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 MOVING TO WORK DEMONSTRATION PROGRAM $293.77M
14.879 MAINSTREAM VOUCHERS $10.18M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $9.68M
14.267 CONTINUUM OF CARE PROGRAM $3.61M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $3.41M
14.182 LOWER INCOME HOUSING ASSISTANCE PROGRAM_SECTION 8 NEW CONSTRUCTION/SUBSTANTIAL REHABILITATION $2.91M
14.870 Resident Opportunity & Supportive Services $830,008
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $763,116
14.895 JOBS-PLUS PILOT INITIATIVE $387,394
14.249 SECTION 8 MODERATE REHABILITATION SINGLE ROOM OCCUPANCY $188,406
14.892 CHOICE NEIGHBORHOODS PLANNING GRANTS $150,000
14.191 MULTIFAMILY HOUSING SERVICE COORDINATORS $71,557
14.419 SECTION 3 COORDINATION AND IMPLEMENTATION $15,548