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