Finding 1219553 (2025-002)

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 complying with HUD requirements for tenant eligibility, leading to potential inaccuracies in rental assistance payments.
  • Impacted Requirements: Internal controls outlined in the MTW Annual Plan and 24 CFR 982.516 are not being followed, affecting the accuracy of tenant files.
  • Recommended Follow-Up: The Agency should review and improve its procedures, correct identified deficiencies, and assess the impact on the entire tenant population.

Finding Text

Eligibility Moving to Work Demonstration Program AL No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Repeated from 2024 audit (see prior year finding 2024-002) Condition: Out of an approximate population of approximately 4,800 tenants, 40 tenant files were tested and the following deficiencies were noted: • Two files did not have 214 documentation available for a member of the household, • One file had the incorrect income calculation, which impacted the HAP received, • One file had the incorrect income calculation, which did not impact the HAP received, • One file received the incorrect HAP for which no subsequent correction was made, and • One file did not have a required rent reasonableness performed during the year. Criteria: The Agency’s Moving to Work (“MTW”) Annual Plan, 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: $17,280. 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 Moving to Work Demonstration Program AL. No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Reported from 2024 audit (see prior year finding 2024-002) Condition: Out of an approximate population of approximately 4,800 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Two files did not have 214 documentation available for a member of the household, ▪ One file had the incorrect income calculated, which impacted the HAP received, ▪ One file had the incorrect income calculated, which did not impact the HAP received, ▪ One file received the incorrect HAP for which no subsequent correction was made, ▪ One file did not have a required rent reasonableness performed during the year, and ▪ One file did not have a quality control checklist maintained in the file. 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 Due Date Responsible Person Conduct a review of cases with identified audit findings to confirm the accuracy of the determinations and implement corrections as needed. Eligibility checklists were implemented on July 31, 2024, in response to the FY23 audit findings. An additional checklist specific to annual and recertification processes was implemented in October 2025 to further strengthen compliance and quality control. Some households are on a triannual recertification cycle and have not undergone a recertification since the prior audit; these cases will be reviewed as applicable. The accuracy and effectiveness of all checklists will be reviewed and updated as needed by August 31, 2026. September 30, 2026 Program Manager, Christi Champ To address findings related to incorrect income calculations, the agency conducts monthly quality assurance reviews through random case sampling, consistent with HUD-recommended practices. 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. September 30, 2026 Program Manager, Christi Champ The file identified as missing required rent reasonableness documentation will be reviewed, and any deficiencies will be corrected as appropriate. Based on internal review, this case may be associated with a Project-Based Voucher (PBV) unit, where prior rent increases were appropriately completed but not consistently retained within the tenant file. In Spring 2026, the agency identified this documentation gap and implemented process improvements, including updates to internal policies to ensure that all rent reasonableness determinations are consistently documented and maintained September 30, 2026 Program Manager, Christi Champ in the tenant file. These updates will be effective July 2026. All required rent reasonableness documentation will be added to the applicable tenant file

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1219550 2025-003
    Material Weakness Repeat
  • 1219551 2025-003
    Material Weakness Repeat
  • 1219552 2025-003
    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