Finding 1225858 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-08-05

AI Summary

  • Core Issue: The Authority is not maintaining tenant files properly, leading to material non-compliance with eligibility requirements for the Housing Voucher Cluster programs.
  • Impacted Requirements: Essential documents like income verification and signed leases were missing from tenant files, violating federal regulations (24 CFR sections 5.230, 5.609, and 982.516).
  • Recommended Follow-Up: Hire and train staff on tenant file maintenance to ensure all necessary documents are collected, stored, and safeguarded for compliance.

Finding Text

Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871 & 14.879 Non Compliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,208 units. Of a sample size of thirty-four (34) tenant files, the following was noted: HUD form 9886 was unable to be provided in 2 files Citizen Declaration Section 214 form was unable to be provided in 4 files Signed lease was unable to be provided in 4 files Lead based paint form was unable to be provided in 1 file, Known Questioned Costs: $19,212 Cause: There is a material weakness in internal controls over the eligibility type of compliance related to the maintenance of tenant files in the Housing Voucher Cluster. The Authority experienced high turnover and did not properly train employees in the HCV department, which resulted in the Authority having a limited capacity to perform the required maintenance of tenant files, and properly maintain and monitor a system of internal controls that reasonably assures the program is in compliance. Effect: The Authority is in material non-compliance with the eligibility requirements of the Housing Voucher Cluster programs. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on tenant file maintenance so that documents are accumulated, stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies related to the administration of Housing Voucher Cluster and will train staff on the proper maintenance of tenant files and implement internal control procedures that will ensure compliance with federal regulations.

Corrective Action Plan

Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871 & 14.879 Non Compliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,208 units. Of a sample size of thirty-four (34) tenant files, the following was noted: • HUD form 9886 was unable to be provided in 2 files • Citizen Declaration Section 214 form was unable to be provided in 4 files • Signed lease was unable to be provided in 4 files • Lead based paint form was unable to be provided in 1 file Known Questioned Costs: $19,212 Cause: There is a material weakness in internal controls over the eligibility type of compliance related to the maintenance of tenant files in the Housing Voucher Cluster. The Authority experienced high turnover and did not properly train employees in the HCV department, which resulted in the Authority having a limited capacity to perform the required maintenance of tenant files, and properly maintain and monitor a system of internal controls that reasonably assures the program is in compliance. Effect: The Authority is in material non-compliance with the eligibility requirements of the Housing Voucher Cluster programs. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on tenant file maintenance so that documents are accumulated, stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies related to the administration of Housing Voucher Cluster and will train staff on the proper maintenance of tenant files and implement internal control procedures that will ensure compliance with federal regulations. Tonya Crawley, HCV Program Director is responsible for ensuring proper internal controls are in place to prevent material weaknesses from occurring and is expected to be completed by December 31, 2026.

Categories

HUD Housing Programs Questioned Costs Eligibility Material Weakness

Other Findings in this Audit

  • 1225856 2025-002
    Material Weakness Repeat
  • 1225857 2025-003
    Material Weakness Repeat
  • 1225859 2025-003
    Material Weakness Repeat
  • 1225860 2025-004
    Material Weakness Repeat
  • 1225861 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $30.95M
14.892 CHOICE NEIGHBORHOODS PLANNING GRANTS $11.47M
14.850 PUBLIC HOUSING OPERATING FUND $8.07M
14.872 PUBLIC HOUSING CAPITAL FUND $6.40M
14.895 JOBS-PLUS PILOT INITIATIVE $472,752
14.879 MAINSTREAM VOUCHERS $262,428
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $94,725
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $40,440