Finding 1214234 (2025-009)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-05-08

AI Summary

  • Core Issue: The Authority failed to evaluate and document reasonable rent for newly leased units, leading to non-compliance with federal requirements.
  • Impacted Requirements: Compliance with rent reasonableness evaluations at initial leasing and during contract terms, as outlined in federal regulations.
  • Recommended Follow-Up: Implement training and procure software to ensure staff can effectively perform rent reasonableness evaluations and maintain compliance.

Finding Text

Finding 2025-009: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 and 14.EHV Noncompliance – N. Special Tests and Provisions - Reasonable Rent Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Reasonable Rent. The Authority must do the following: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)(24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: Based upon inspection of the Authority’s files and discussion with management, the Authority did not have procedures or software in place to perform the required evaluation of rent reasonableness. Context: There were approximately fifteen(15) newly leased units in the Emergency Housing Vouchers Program. Of a sample size of two (2) newly leased units in the Emergency Housing Vouchers Program, documentation of reasonable rent for the two (2) units was not available for examination. Our sample size is statistically valid. Known Questioned Costs: Unknown Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to reasonable rent. The Authority experienced high turnover and did not properly train employees in the HCV department, which resulted in the Authority having a limited capacity to perform rent reasonableness calculations and properly maintain and monitor a system of internal controls that reasonably assures the program is in compliance with program requirements. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to reasonable rent. Recommendation: We recommend that the Authority procure software and implement a process whereby Authority personnel are hired and trained on performing the appropriate rent reasonableness procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies in the Section 8 Housing Voucher Cluster programs and will train staff on rent reasonableness and implement internal control procedures that will ensure compliance with federal regulations.

Corrective Action Plan

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 and 14.EHV Noncompliance – N. Special Tests and Provisions - Reasonable Rent Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Reasonable Rent. The Authority must do the following: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: Based upon inspection of the Authority’s files and discussion with management, the Authority did not have procedures or software in place to perform the required evaluation of rent reasonableness. Context: There were approximately fifteen(15) newly leased units in the Emergency Housing Vouchers Program. Of a sample size of two (2) newly leased units in the Emergency Housing Vouchers Program, two (2) unit's documentation of reasonable rent was not available for examination. Our sample size is statistically valid. Known Questioned Costs: Unknown Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to reasonable rent. The Authority experienced high turnover and did not properly train employees in the HCV department, which resulted in the Authority having a limited capacity to perform rent reasonableness calculations and properly maintain and monitor a system of internal controls that reasonably assures the program is in compliance with program requirements. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to reasonable rent. Recommendation: We recommend that the Authority establish a software and implement a process whereby Authority personnel are hired and trained on performing the appropriate rent reasonableness procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies in the Section 8 Housing Voucher Cluster Programs and will train staff on rent reasonableness and implement internal control procedures that will ensure compliance with federal regulations. Malcom Isler, HCV Program Director/Interim Deputy Executive Director is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring and is expected to be completed by July 31, 2026.

Categories

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 1214230 2025-008
    Material Weakness Repeat
  • 1214231 2025-005
    Material Weakness Repeat
  • 1214232 2025-006
    Material Weakness Repeat
  • 1214233 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $13.56M
14.872 PUBLIC HOUSING CAPITAL FUND $10.80M
14.850 PUBLIC HOUSING OPERATING FUND $8.85M
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $106,918