Finding 1217746 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-16
Audit: 403877
Organization: Albion Housing Commission (MI)

AI Summary

  • Core Issue: 36% of tenant files reviewed had errors in rent calculations due to lack of secondary reviews.
  • Impacted Requirements: Non-compliance with 24 CFR section 960.259 and 24 CFR 85.20 regarding eligibility verification and internal controls.
  • Recommended Follow-Up: Implement internal controls and a secondary review process for tenant files to ensure accurate rent calculations and compliance.

Finding Text

Subject: Public Housing Operating Fund – Tenant Eligibility and Reexaminations Federal Agency: Department of Housing and Urban Development Federal Program: Public Housing Operating Fund Assistance Listing Number: 14.850 Federal Award Number and Year (or Other Identifying Number): CY 2025 Pass-Through Entity: Not applicable Compliance Requirement: Eligibility Audit Finding: Material Weakness and Material Noncompliance Condition and Context: Of the 22 public housing tenant files reviewed, 8 tenant files contained errors resulting in miscalculated tenant rent (36%). It was noted the Commission does not perform a secondary review of annual rent certifications resulting in tenant rent errors. Criteria: 24 CFR section 960.259 requires the Commission to obtain and document in the family file third-party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. 24 CFR 85.20 requires the Commission to have effective internal controls, and accountability must be maintained for all funds. Cause: Lack of internal controls over tenant files. Effect: Non-compliance with the federal Eligibility requirement. Tenant rents may be miscalculated, other notifications and documentation may be missing. Tenant rents were undercharged, resulting in noncompliance with HUD eligibility requirements and a loss of rental revenue to the Commission. Questioned Cost: We performed an extrapolation of the undercharged rent based on our reviewed sample of tenant files. This resulted in likely questioned costs of $77,086, which reflects 9.9% of total rental income. Recommendation: The Commission should implement internal controls over tenant files to ensure accountability. All certifications and the required documentation should be maintained in the tenant's current file. Additionally, in order to ensure certifications are performed timely and tenant information is input correctly, the Commission should have a second party review files in a timely manner.

Corrective Action Plan

Condition Identified: During the audit review of 22 tenant files, 8 files contained errors resulting in miscalculated tenant rent. The audit further identified that the Commission did not have an adequate secondary review process for annual rent certifications, resulting in errors in tenant rent calculations and missing documentation. Corrective Action Plan The Albion Housing Commission acknowledges the findings and is committed to strengthening internal controls and improving oversight procedures to ensure compliance with HUD regulations and accuracy in tenant rent determinations. The employee primarily responsible for maintaining and processing tenant files during the audit period is no longer employed by the Commission. Management has since evaluated its procedures and is implementing corrective measures to prevent future occurrences. Planned Corrective Actions 1. Implementation of Secondary Review Process Effective immediately, all annual and interim rent certifications will undergo a mandatory second-party review by management or a designated qualified staff member prior to final approval. 2. Third Party File Review 3. Staff Training and Management Improvement 4. Strengthening Internal Controls 5. Monitoring and Compliance

Categories

HUD Housing Programs Subrecipient Monitoring Eligibility Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $728,061
14.872 PUBLIC HOUSING CAPITAL FUND $427,758