Finding 1211180 (2024-004)

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: The Authority has significant deficiencies in tenant file management, including missing recertifications and incorrect income documentation.
  • Impacted Requirements: Noncompliance with 24 CFR 983.353, which mandates accurate and timely tenant file procedures as per HUD standards.
  • Recommended Follow-Up: The Authority should review and improve internal controls, address the noted deficiencies, and assess the impact on all tenant files.

Finding Text

Eligibility Section 8 Project-Based Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 240 of tenants, 11 tenant files were tested and the following deficiencies were noted: • Four files did not have annual recertifications performed during the year, • Two files did not have a 214 declaration form for all members of the household, • Two files used incorrect income based on the support provided during the annual recertification, • One file did not have documentation necessary to verify the reported income, and • One files did not have utility allowance documentation. Criteria: 24 CFR 983.353 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 randomly selected tenant files out of the population 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 Section 8 Project-Based Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 240 of tenants, 11 tenant files were tested and the following deficiencies were noted: Four files did not have annual recertifications performed during the year, Two files did not have a 214 declaration form for all members of the household, Two files used incorrect income based on the support provided during the annual recertification, One file did not have documentation necessary to verify the reported income, and One files did not have utility allowance documentation. 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.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1211170 2024-001
    Material Weakness Repeat
  • 1211171 2024-002
    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
  • 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