Finding 1235860 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-09-21

AI Summary

  • Core Issue: Thirty-five out of fifty-five tenant files were found noncompliant, primarily due to errors in income verification and late reexaminations.
  • Impacted Requirements: Compliance with Title 24 regulations and HUD guidelines is critical for accurate income verification and timely inspections.
  • Recommended Follow-Up: Enhance quality control monitoring, continue third-party assistance for reexaminations, and contract an independent inspector to address inspection backlogs.

Finding Text

Finding 2025-001 – Public Housing Tenant Files – Eligibility – Internal Control over Tenant Files Noncompliance and Material Weakness – Low Income Public Housing – ALN 14.850 Condition & Cause: We randomly selected fifty-five (55) tenant files for review. We noted thirty-five (35) tenant files were out of compliance in one or more categories. Of these, eleven (11) files, or 20%, were impacted by errors related to adjusted annual income. Based on these errors, we extrapolated the potential rental charge misstatement and found it represented approximately 0.9% of total program rental revenue, which is immaterial to the financial statements. The counts below reflect total instances per category, not unique files. In our review, we noted: • Nine (9) files had improper or missing income verification; • Three (3) files contained a miscalculation of annual income; • Three (3) files contained improper or unverified deductions from annual income; • Eighteen (18) annual reexaminations were completed more than three months past the due date; • Fifteen (15) files lacked documentation of required unit inspections; • Seven (7) files were missing the required Enterprise Income Verification (EIV) report at the annual reexamination, or the reports were generated significantly after the effective date; • Three (3) files were missing a completed 9886 or 9886-A; • One (1) file did not contain an application for continued occupancy at the annual reexamination. Agency management attributed these deficiencies to significant staff turnover during the past several years. It should be noted that, as a mitigating action, the Agency has contracted with a third-party vendor for assistance in processing reexaminations and is currently soliciting a contract for an independent inspector. Criteria: Title 24 of the Code of Federal Regulations, the Housing Authority’s Admissions and Continued Occupancy Policy, and specific HUD guidelines in documenting and maintaining the Public Housing tenant files. Effect: Failure to properly verify and calculate tenant income can result in misstatements of dwelling rental income and the operating subsidy earned by the Housing Authority. Late reexaminations delay the identification of changes in tenant income and household composition, increasing the risk that tenants are charged incorrect rent for extended periods. The lack of timely unit inspections compromises the Agency’s ability to ensure that units are free of health and safety hazards. Additionally, continued compliance exceptions increase the Agency’s exposure to heightened regulatory scrutiny from HUD. Recommendation: The Authority has implemented QC processes for most reexaminations; however, timeliness remains an issue. We recommend enhancing QC monitoring to flag files before deadlines lapse, continuing third-party support to bring overdue reexaminations current, and continue providing targeted staff training to address income calculation and verification errors. Regarding inspections, we recommend the Authority proceed with contracting an independent inspector and develop a plan with target dates to eliminate the current backlog. Going forward, the Authority should implement procedures, such as cross-training, temporary assignments, or continued use of third-party inspectors, to ensure inspections remain timely during staff turnover or vacancies. Questioned Costs: None Repeat Finding: Yes Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

FINDING 2025-001 "Public Housing Tenant Files - Eligibility- Internal Control Over Tenant Files Non-Compliance and Material Weakness" SHA RESPONSE The Springfield Housing Authority acknowledges the eleven (11) errors as delineated in the full 2025 FYE audit report accounting for twenty (20) percent of files reviewed that were impacted by errors related to adjusted annual income. In 2025, the Springfield Housing Authority Public Housing program identified the following positions to undertake income and rent calculations: three (3) Occupancy Specialists, three (3) Asset Managers and one (1) Program Integrity Specialist. The primary function of the Program Integrity Specialist position is to audit and quality control tenant files and rent calculations conducted by Occupancy Specialists. The Asset Managers are responsible for reviewing 3% of recertifications audited by the Program Integrity Specialist position as an additional quality control measure. The errors were primarily attributable to staffing shortages, former staff, lack of qualified candidates in the local workforce, unprecedented staff turnover resulting in the subsequent continuity and disruption in caseload management. The SHA has taken and will continue to take corrective actions to address the underlying causes and strengthen the rent calculation process. In addition to the plan of action listed below, corrective actions include but are not limited to: pursuing alternative recruitment options; training/cross training staff responsible for rent calculations, ensuring staff responsible for rent calculations receive refresher training on applicable policies, procedures and calculation requirements as well as additional external rent calculation training; management quality control reviews will provide additional scrutiny for higher-risk and more complex files. The SHA recognizes that staffing challenges may not be eliminated, accordingly, these corrective actions are intended to address both the immediate errors identified in the audit and the underlying process weaknesses that contributed to the errors. The SHA will closely monitor implementation of these measures to ensure that rent calculations are accurate, properly documented and completed in accordance with applicable requirements. The Asset Managers, Occupancy Specialists and Program Integrity Specialists were provided additional internal and external training opportunities in low rent public housing rent calculations and program integrity in 2025 and 2026. In addition to the aforementioned, the SHA will take the following corrective actions to correct the errors and/or prevent the errors moving forward: • The Program Integrity Specialist will conduct reviews of 100% of annual and interim recertifications for public housing tenants by December 31, 2026. A formal quality control review log has been established with on-going implementation. • The Program Integrity Specialist will ensure---1 0% a1:.1ditea file corrections are completed by the Occupancy Specialists, monthly. • The Asset Manager(s} will review 10% of the recertifications audited by the Program Integrity Specialist as an additional quality control measure by December 31, 2026. • Any newly hired Asset Managers, Occupancy Specialists and Program Integrity Specialists will receive additional external training in low rent public housing rent calculations and program integrity within sixty (60} days of employment. • The Asset Managers will re-review the files identified with errors during the independent audit and resolve the errors in accordance with the SHA Admissions and Continued Occupancy Plan and HUD rules and regulations by December 31, 2026. • Upon identifying the occurrence of late reexams in Public Housing operations, the Springfield Housing Authority hired third party consultants to assist with processing annual recertifications 1st Quarter of 2026 that continued through July 2026. Based on the success of this process within the HCV division in 2026, the Springfield Housing Authority issued a Request for Proposal and awarded a contract to a third-party contractor to assist in completion of 2026 recertifications as a consistent measure while the Public Housing and HCV departments hire, train and onboard new staff. • Further, upon identifying the FY2025 annual inspections were not fully completed by SHA Inspection staff, the Springfield Housing Authority issued a Request for Proposal for a third-party vendor to complete 100% annual inspections and assist with NSPIRE standards training and evaluation of SHA properties. The Springfield Housing Authority anticipates contract award September 2026 to address the outstanding unit inspections portion of the audit finding. Person Responsible: Monica Johnson, Asset Manager Anticipated Completion Date: December 31, 2026

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1235861 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $3.89M
14.872 PUBLIC HOUSING CAPITAL FUND $2.95M
14.879 MAINSTREAM VOUCHERS $1.26M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $326,758
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $249,424
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $2,257