Finding 1238765 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: The PHA failed to document rent reasonableness evaluations for 3 out of 22 cases, particularly during contract terms when evaluations were required.
  • Impacted Requirements: Compliance with regulations regarding rent evaluations, including maintaining records that justify rent determinations based on unit attributes and market comparisons.
  • Recommended Follow-Up: Establish a process to ensure all rent evaluations are conducted and documented properly, especially during transitions to digital record-keeping.

Finding Text

2025-002 – Significant Deficiency – Internal Control over Compliance Criteria: The PHA administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority was unable to provide documentation of appropriate evaluation of rent reasonableness procedures for 3 of 22 selections made. The 3 selections specifically were instances where the evaluations were during the term of the contract when the circumstance indicated an evaluation should be completed. Cause: The Authority did not properly ensure documentation was maintained for rent evaluation reasonableness during the transitions from physical files to digital file maintenance. Effect or Potential Effect: Because documentation could not be located we were unable to determine if the evaluations of rent reasonableness was appropriately completed for 3 of the 22 selections tested. Recommendations: We would recommend the Authority implement a process to ensure all rent reasonableness evaluations are completed as required, and documentation to support the evaluation process and conclusion is appropriately maintained within the tenant and/or property files. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding outlined and is working to implement necessary changes to ensure compliance and appropriate internal controls are operating effectively.

Corrective Action Plan

2025-002 – Housing Voucher Cluster: Special Tests and Provisions – Reasonable Rent – ALN #14.871 Significant Deficiency Criteria: The PHA administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority was unable to provide documentation of appropriate evaluation of rent reasonableness procedures for 3 of 22 selections made. The 3 selections specifically were instances where the evaluations were during the term of the contract when the circumstance indicated an evaluation should be completed. Cause: The Authority did not properly ensure documentation was maintained for rent evaluation reasonableness during the transitions from physical files to digital file maintenance. Effect or Potential Effect: Because documentation could not be located we were unable to determine if the evaluations of rent reasonableness was appropriately completed for 3 of the 22 selections tested. Known Questioned Costs: $0 Recommendations: We would recommend the Authority implement a process to ensure all rent reasonableness evaluations are completed as required, and documentation to support the evaluation process and conclusion is appropriately maintained within the tenant and/or property files. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding outlined and is working to implement necessary changes to ensure compliance and appropriate internal controls are operating effectively.

Categories

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $2.32M
10.415 RURAL RENTAL HOUSING LOANS $807,216
14.850 PUBLIC HOUSING OPERATING FUND $382,033
14.872 PUBLIC HOUSING CAPITAL FUND $231,403
10.427 RURAL RENTAL ASSISTANCE PAYMENTS $217,690
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $61,043