Finding 1238040 (2025-001)

Material Weakness Repeat Finding
Requirement
Eligibility
Questioned Costs
-
Year
2025
Accepted
2026-09-29

AI Summary

  • Core Issue: The Housing Authority of the City of Pittsburgh has repeated failures in internal controls, leading to delays and missing documentation for tenant recertifications.
  • Impacted Requirements: Compliance with HUD requirements for timely and accurate completion of Form HUD-50058, which is essential for determining tenant eligibility and calculating rental assistance.
  • Recommended Follow-Up: Implement stronger procedures for timely recertification, ensure all supporting documents are collected, and provide training to prevent future lapses in internal controls.

Finding Text

Finding 2025-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021 (2021-001), 2022 (2022-001), 2023 (2023-001), and 2024 (2024-001) Condition: During our review of 40 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls, evidenced by 4 of the Authority’s internal control checklists not being completed or unable to be provided for audit, which led to the below exceptions in our testing. We noted two instances where a tenant recertification using the Form HUD-50058, Family Report (Form) (which provides eligibility and reporting information) was not completed on a timely basis. We also noted three instances where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 was not provided. This includes items such as support for income calculation and medical deductions. These exceptions indicate a lack of functioning internal controls and oversight to ensure compliance with HUD requirements related to timely and accurate tenant recertifications. Criteria: The Authority is required to prepare and submit the Form each time the Authority completes an admission, bi-annual reexamination, portability move-in, or other change of unit for a family. The form provides HUD and the Authority with vital eligibility data for each program participant such as family composition, family income, the assets and liabilities of program participants, and ultimately provides for the calculation of tenant rent and rental/housing assistance payments for each program participant. In relation to the missing documents noted above, these documents are to be maintained to support the eligibility of the tenant, and are also required to be maintained to provide support for the tenant income and eligibility determinations completed on the Form. Cause: There was a lack of functioning internal control over the recertification process that were exacerbated by turnover and logistical staffing challenges in recent years. Effect: The Form provides essential information to HUD as well as being used by the Authority to determine program eligibility. In addition, the Form is used for the calculation of tenant rent and rental/housing assistance payments. Without this required documentation, this could lead to ineligible tenants being housed through the Authority program, and/or overpayments or underpayments of rental assistance, and incorrect information being reported to HUD. Questioned Costs: Not determinable. The Authority provided sufficient documentation to establish that these four individuals qualified for benefits but insufficient documentation to establish the correct benefit amount. Recommendation: We recommend that the Authority implement additional procedures to ensure biennial recertification and the related Forms are prepared timely and accurately and that all supporting documentation is obtained and retained. In addition, appropriate training and planning should be performed to ensure that future turnover in the organization does not lead to a lapse in internal controls over compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.

Corrective Action Plan

Finding 2025-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021 (2021-001), 2022 (2022-001), 2023 (2023-001), and 2024 (2024-001) Maher Duessel Finding Condition: During our review of 40 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls, evidenced by 4 of the Authority’s internal control checklists not being completed or unable to be provided for audit, which led to the below exceptions in our testing. We noted two instances where a tenant recertification using the Form HUD-50058, Family Report (Form) (which provides eligibility and reporting information) was not completed on a timely basis. We also noted three instances where other documentation to support the reporting and eligibility assessment as part of completion of the HUD- 50058 was not provided. This includes items such as support for income calculation and medical deductions. These exceptions indicate a lack of functioning internal controls and oversight to ensure compliance with HUD requirements related to timely and accurate tenant recertifications. HACP Management Response/Action Taken: Finding 2025-001 - Eligibility and Reporting Finding 2025-002 - U.S. Department of Housing and Urban Development Housing Voucher Cluster: Section 8 Housing Choice Vouchers and Mainstream Vouchers- ALNs 14.871 & 14.879 Eligibility and Reporting Summary and Corrective Action Plan: The audit identified continued, internal control weaknesses related to timely recertifications, completion of required internal control checklists, and documentation supporting income calculations and medical deductions. This is a repeat finding from 2021-2024. To address these deficiencies, the HACP plans to go live on October 1st, 2026, with BOB.ai, an artificial intelligence software solution platform built for Public Housing Authorities (PHAs) to assist with tasks to include rent calculations, recertifications, and case management. BOB.ai will support the timely processing and tracking of recertifications, helping to prevent late recertifications and identify outstanding actions before deadlines are missed. The system will also help ensure required forms and supporting documentation are submitted in full before the recertification is processed, reducing the risk of incomplete files and missing eligibility documentation. The HACP Housing Choice Voucher (HCV) Department is evaluating an additional workflow in DocuClass that will include a finalized checklist as part of the recertification workflow. The checklist will confirm that all required documents, eligibility information, and supporting documentation have been received and reviewed before the recertification is finalized. The HACP will utilize system-generated reports to monitor upcoming and overdue recertifications, with management regularly reviewing the reports and addressing outstanding items. Staff must complete all applicable internal control checklists, and supervisors will review files to confirm that required documentation and checklists are complete. The HCV management will perform the following actions to assist with ensuring internal compliance to include the following: Conduct ongoing quality-control reviews and provide staff training on HUD-50058 requirements, documentation standards, and timeliness expectations. • Address recurring deficiencies through documented coaching and corrective action, as appropriate. • Continue to monitor recertification timeliness, documentation completeness, and internal control compliance through monthly reports and file reviews to ensure the corrective actions are effective and prevent recurrence of the finding. • Monitor control functions, staff productivity, work completion, and compliance with established processing timelines. These enhanced monitoring practices have increased management’s ability to identify work that is incomplete, delayed, or otherwise not meeting established performance expectations. • Holding staff accountable through documented coaching, performance management, and disciplinary action, when appropriate, in accordance with applicable HACP policies and procedures. Unfortunately, in some instances, the time required to identify, document, address, and monitor recurring performance deficiencies through the applicable disciplinary process results in work becoming overdue before the HACP can complete the personnel action or otherwise resolve the underlying staffing issue.The HACP recognizes the operational impact of these circumstances and is continuing to strengthen workload monitoring, supervisory oversight, and system-generated alerts. Also, workflow controls are being utilized to identify and address deficiencies as early as possible and minimize the impact of staff turnover and performance-related delays on program operations.

Categories

Eligibility HUD Housing Programs Internal Control / Segregation of Duties Reporting

Other Findings in this Audit

  • 1238041 2025-002
    Material Weakness Repeat
  • 1238042 2025-002
    Material Weakness Repeat
  • 1238043 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 MOVING TO WORK DEMONSTRATION PROGRAM $165.99M
14.889 CHOICE NEIGHBORHOODS IMPLEMENTATION GRANTS $9.24M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $1.40M
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $572,951
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $271,103
14.879 MAINSTREAM VOUCHERS $123,444