Finding 1218323 (2025-004)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-24

AI Summary

  • Core Issue: The Agency did not follow HUD requirements for managing the Section 8 waiting list, leading to potential improper ranking of applicants.
  • Impacted Requirements: Noncompliance with 24 CFR §982 regarding eligibility verification and documentation retention for waitlist preferences.
  • Recommended Follow-Up: Review and update the Administrative Plan, implement verification procedures, and train staff on compliance with waitlist requirements.

Finding Text

Finding 2025-004 – Section 8 Waiting List – Eligibility – Internal Control over Waiting List – Noncompliance and Significant Deficiency – Section 8 Housing Assistance Cluster Program – ALNs 14.871, 14.879, and 14.EHV Condition & Cause: In our review of the Section 8 waiting lists, we found that the Agency did not administer Housing Choice Voucher waitlist preferences in accordance with HUD requirements and its own governing documents. Specifically, the local preferences programmed into their housing database are not included or detailed in the Agency’s Section 8 Administrative Plan. Furthermore, we found that the Agency was unable to provide documentation verifying that applicants met the eligibility criteria for the preferences claimed. The Agency experienced significant staff turnover, including executive and senior management, since the waitlist last accepted applications in 2021. During this period, the Agency did not ensure continuity of policies and internal controls related to waitlist administration. As a result, local preferences programmed into the housing software were not reconciled to the Administrative Plan, and procedures were not in place to ensure consistent verification and retention of documentation supporting applicants’ claimed preferences. Criteria: 24 CFR §982 details the requirements of administering the Housing Choice Voucher waitlist. Effect: The Agency cannot demonstrate that applicants were selected from the waitlist in accordance with HUD regulations and the Agency’s Administrative Plan. This condition increases the risk that applicants may have been improperly ranked or selected, undermining the integrity, transparency, and fairness of the waitlist process. Recommendation: We recommend that the Agency first review all local preferences currently programmed in the housing database and either remove those not formally adopted or update the Admin Plan to accurately reflect all preferences used. Second, implement procedures to ensure that staff obtain, verify, and retain documentation supporting applicants’ eligibility for any claimed waitlist preference. Furthermore, provide staff training on waitlist preference requirements and record retention to ensure consistent compliance with HUD regulations and the Admin Plan. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

Finding 2025-004 – Section 8 Waiting List – Eligibility – Internal Control over Waiting List – Noncompliance and Significant Deficiency – Section 8 Housing Assistance Cluster Program – ALNs 14.871, 14.879, and 14.EHV 1. Standardized Waiting List Procedures The agency will establish and enforce standardized procedures for: • Application intake (date/time stamping) • Placement order and preference verification • Updating applicant status • Removal and reinstatement processes All procedures will align with program regulations and be clearly documented. 2. Waiting List Management System Controls The agency will implement or strengthen controls within its waiting list system to ensure: • Automatic date/time tracking of applications • Secure user access with role-based permissions • Audit trails showing all changes (additions, updates, removals) Manual logs will be maintained if system functionality is limited. 3. Periodic Waiting List Updates & Purging The waiting list will be updated regularly to maintain accuracy: • Scheduled update notices (e.g., annually or biannually) • Proper documentation of applicant responses • Removal of ineligible or unresponsive applicants with documented justification 4. Supervisory Review & Oversight A supervisor will conduct routine reviews of waiting list activities, including: • Verification of proper placement and preferences • Review of removals and selections • Approval of any deviations from standard procedures 5. Staff Training All HCV staff involved in waiting list management will receive training on: • HUD and agency requirements • Preferences and ranking procedures • Proper documentation and recordkeeping • Fair housing compliance Refresher training will be conducted periodically. 6. Internal Quality Control Monitoring The agency will conduct periodic internal audits of the waiting list to ensure: • Compliance with policies • Accurate applicant ranking • Proper documentation of all actions Findings will be documented, and corrective actions will be implemented promptly. 7. Policy & Administrative Plan Updates The agency has revise its Administrative Plan to include: • Detailed waiting list procedures • Internal control measures • Selection and preference verification processes All updates will be approved and communicated to staff. 8. Documentation Retention The agency will maintain complete documentation for: • Applications received • Preferences verified • Correspondence with applicants • Reasons for removal or denial Files will be retained in accordance with recordkeeping requirements. Person Responsible- Consuela Knight, Director of HCV Programs Anticipated Completion Date - September 30, 2026

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1218315 2025-001
    Material Weakness Repeat
  • 1218316 2025-001
    Material Weakness Repeat
  • 1218317 2025-002
    Material Weakness Repeat
  • 1218318 2025-003
    Material Weakness Repeat
  • 1218319 2025-003
    Material Weakness Repeat
  • 1218320 2025-003
    Material Weakness Repeat
  • 1218321 2025-004
    Material Weakness Repeat
  • 1218322 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $4.34M
14.872 PUBLIC HOUSING CAPITAL FUND $1.19M
14.267 CONTINUUM OF CARE PROGRAM $386,404
14.879 MAINSTREAM VOUCHERS $242,865
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $189,317
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $138,573
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $49,152