Finding 1219552 (2025-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-26
Audit: 405133
Organization: Homes for Good Housing Agency (OR)

AI Summary

  • Core Issue: The Agency is not fully compliant with HUD requirements for tenant file management, with several deficiencies identified in a sample of 40 files.
  • Impacted Requirements: Internal controls as per the Agency’s Administrative Plan and 24 CFR 982.516 are lacking, affecting timely and accurate tenant documentation.
  • Recommended Follow-up: The Agency should review and improve procedures to address the noted deficiencies and assess the impact on all tenant files, not just those sampled.

Finding Text

Eligibility Housing Voucher Cluster Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of an approximate population of approximately 600 tenants, 40 tenant files were tested and the following deficiencies were noted: • Four files did not have an inspection performed during the required period, • Two files did not have an up to date 9886 form on file, • One file did not have ID for an adult tenant in the household, and • One file had the incorrect income calculation, which did not impact the HAP received. Criteria: The Agency’s Administrative Plan and 24 CFR 982.516 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 haphazardly selected 40 tenants 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 Agency is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Agency experienced staffing and operational challenges, which is impacting the housing industry as a whole and did not have the available staff to follow the established internal controls to ensure proper compliance with regards to recertifications and collection of required HUD documentation to verify eligibility and calculate accurate housing assistance payments. Effect: The Agency 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 Agency should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. The Agency 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 Housing Voucher Cluster Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of an approximate population of approximately 600 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Four files did not have an inspection performed during the required period, ▪ Two files did not have an up to date 9886 form on file ▪ One file did not have ID for an adult tenant in the household, and ▪ One file had the incorrect income calculated, which did not impact the HAP received. Auditor Recommendations: The Authority should re-evaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. 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: Action Due Date Responsible Person Conduct a review of cases associated with inspectionrelated findings to verify the accuracy of the determinations and implement corrections as necessary. In certain cases, inspections may align with approved biennial inspection schedules, or delays may have occurred due to inability to access the unit or tenant non-compliance. In such instances, cases may currently be progressing through the ineligibility process, which requires additional time to resolve in accordance with program requirements. Additionally, the agency identified system-related reporting issues within Yardi that may have impacted the September 30, 2026 Program Manager, Nat Dybens accuracy of inspection tracking reports. The agency has been actively collaborating with system coordinators to address and resolve these issues. Files identified as lacking an upto-date Form HUD-9886 will be reviewed to confirm the accuracy of the finding, and all required documentation will be obtained and maintained in the tenant file to ensure compliance. Form HUD-9886-A [24 CFR 5.230(b)(1), b(2), (c)(4), and (c)(5)]; Notice PIH 2023-27 All adult applicants and participants sign form HUD-9886- A, Authorization for Release of Information. All adult family members (and the head and spouse/cohead, regardless of age) are required to sign the Form HUD9886-A at admission. Participants, prior to January 1, 2024, signed and submitted Form HUD9886 at each annual reexamination. HOTMA eliminated this requirement and instead required that the Form HUD-9886-A be signed only once. On or after January 1, 2024 (regardless of the PHA’s HOTMA compliance date), current program participants must sign and submit a new Form HUD-9886-A at their next interim or annual reexamination. This form will only be signed once. Another Form HUD-9886-A will not be submitted to the PHA except under the following circumstances: • When any person 18 years or older becomes a member of the family; • When a current member of the family turns 18; or • As required by HUD or the PHA in administrative instructions. September 30, 2026 Program Manager, Christi Champ The PHA has the discretion to establish policies around when family members must sign consent forms when they turn 18. PHAs must establish these policies stating when family members will be required to sign consent forms at intervals other than at reexamination. PHA To address areas of identified findings, the agency will reinforce expectations through staff reminders and provide additional training as needed. Additionally, beginning in March 2026, the agency initiated comprehensive refresher trainings for all Housing Specialist (HS) staff, covering core program functions and requirements. These trainings are scheduled for completion by the end of July 2026. Continued throughout the year. Program Manager, Christi Champ and Program Manager, Nat Dybens The file identified as missing required identification documentation for an adult household member will be reviewed to verify the accuracy of the finding, and all necessary documentation will be obtained and updated as appropriate. The agency recognizes that there are multiple acceptable methods for verifying adult identity and will ensure that documentation on file meets HUD requirements and is properly maintained. Additionally, a recertification checklist was implemented in October 2025 to support staff in verifying the presence of all required permanent documentation, including identification, during case file reviews. This control strengthens ongoing compliance and reduces September 30, 2026 Program Manager, Christi Champ the likelihood of similar deficiencies.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1219550 2025-003
    Material Weakness Repeat
  • 1219551 2025-003
    Material Weakness Repeat
  • 1219553 2025-002
    Material Weakness Repeat
  • 1219554 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 MOVING TO WORK DEMONSTRATION PROGRAM $40.66M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $2.42M
10.415 RURAL RENTAL HOUSING LOANS $1.89M
14.879 MAINSTREAM VOUCHERS $1.70M
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $1.18M
14.238 SHELTER PLUS CARE $874,359
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $870,277
14.103 INTEREST REDUCTION PAYMENTS RENTAL AND COOPERATIVE HOUSING FOR LOWER INCOME FAMILIES $539,270
14.182 Section 8 New Construction and Substantial $334,520
10.427 RURAL RENTAL ASSISTANCE PAYMENTS $273,602
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $247,592
64.024 VA HOMELESS PROVIDERS GRANT AND PER DIEM PROGRAM $108,742
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $83,690
97.049 PRESIDENTIAL DECLARED DISASTER ASSISTANCE - DISASTER HOUSING OPERATIONS FOR INDIVIDUALS AND HOUSEHOLDS $63,475
14.267 CONTINUUM OF CARE PROGRAM $54,521