Finding 1219169 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-26

AI Summary

  • Core Issue: The Authority failed to perform required rent reasonableness evaluations for newly leased Section 8 units, leading to non-compliance.
  • Impacted Requirements: Compliance with federal regulations on reasonable rent evaluations at initial leasing and during contract terms was not maintained.
  • Recommended Follow-Up: Implement internal control procedures to ensure all rent evaluations are conducted and documented as per compliance standards.

Finding Text

Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Federal Assistance Listing Numbers: 14.871 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 discussions with management, there were newly leased units for which rent reasonableness evaluations were not performed. Context: There were approximately seventeen (17) newly leased Section 8 Housing Choice Voucher units. Of a sample size of two (2) newly leased units, rent reasonableness evaluations for one (1) unit was not performed. Our sample size is statistically valid. Known Questioned Costs: Amount is below threshold of $25,000. 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. Existing controls were not properly designed, implemented, or maintained to ensure that rent reasonableness requirements are consistently met. 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 the Authority design and implement internal control procedures that ensure all rent reasonableness determinations are performed and documented, in compliance with Uniform Guidance and the compliance supplement.

Corrective Action Plan

Authority's Response and Planned Corrective Action: The Authority acknowledges the deficiencies identified in the Section 8 Housing Choice Vouchers program and has implemented internal control procedures to ensure compliance with federal regulations. The Auditor selected two files out of 17 leased units in the Audit period. In one, the Rent Reasonableness verification documentation was missing. HHA staff will review all 17 newly leased units from the Audit period to assure compliance. In addition, HHA has implemented a system for all new lease ups to assure full compliance with Rent Reasonableness documentation. This includes the Assistant Director of Management reviewing all files before a unit is leased. Marc A. Recko, Executive Director was designated to be responsible for implementing this corrective action by September 30, 2026.

Categories

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 1219168 2025-001
    Material Weakness Repeat
  • 1219170 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $7.67M
14.872 PUBLIC HOUSING CAPITAL FUND $6.16M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $5.55M
14.269 HURRICANE SANDY COMMUNITY DEVELOPMENT BLOCK GRANT DISASTER RECOVERY GRANTS (CDBG-DR) $3.04M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $319,292
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $114,199