Finding 12486 (2022-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-06-25
Audit: 16957
Organization: Sanford Housing Authority (NC)

AI Summary

  • Core Issue: The Authority has repeated compliance failures in tenant eligibility documentation for Section 8 housing, impacting 25 out of 573 tenant files.
  • Impacted Requirements: Noncompliance with HUD regulations (24 CFR 982.516) regarding tenant file accuracy and internal controls, leading to potential errors in rent and HAP payments.
  • Recommended Follow-Up: Implement corrective actions for identified deficiencies, establish ongoing quality control reviews, and enhance staff training and management oversight.

Finding Text

2022-001 Eligibility ? Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 ? Housing Choice Vouchers 14.879 Mainstream Vouchers Material Weakness in Internal Control, Material Noncompliance Repeat finding of finding 2021-002 from the prior year September 30, 2021 Condition: Out of a total tenant population of approximately 573 tenants, 25 files were selected for testing. Exceptions were noted as follows: ? 1 file that did not contain a 214 affidavit for one member of the household, however they did have a birth certificate showing they were an eligible citizen. ? 2 files where the 214 affidavit was not checked for one member of the household certifying they were an eligible citizen, however they did have birth certificates to verify their citizenship. ? 5 files that did not contain a signed Form 9886 for at least one member of the household age 18 or over. ? 1 file where the tenant?s income was calculated correctly but had the wrong amount reported on the 50058, which would have decreased HAP rent by $11. ? 1 file where the prior year utility allowance schedule was used instead of the current year, however this had no effect on HAP rent. ? 1 file where there was no support that an inspection had been done for a new admission. ? 1 file that did not contain a tenancy addendum to support the contract rent and HAP rent for a tenant with a project-based voucher. ? 2 files where there was no support that an EIV report had been processed. In addition to the above, we noted the following during our new admissions testing (9 new admissions tested): ? 3 files that did not contain a passed inspection completed prior to move-in. ? 1 file that did not contain a signed lease agreement or tenancy addendum. ? 1 file where the request for tenancy approval was not executed until the day after the voucher had expired. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority?s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Procedures to ensure compliance with all of the HUD requirements were not being fully implemented. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

Corrective Action Plan

2022-001 Eligibility ? Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 ? Housing Choice Vouchers 14.879 Mainstream Vouchers Material Weakness in Internal Control, Material Noncompliance Repeat finding of finding 2021-002 from the prior year September 30, 2021 Condition: Out of a total tenant population of approximately 573 tenants, 25 files were selected for testing. Exceptions were noted as follows: ? 1 file that did not contain a 214 affidavit for one member of the household, however they did have a birth certificate showing they were an eligible citizen. ? 2 files where the 214 affidavit was not checked for one member of the household certifying they were an eligible citizen, however they did have birth certificates to verify their citizenship. ? 5 files that did not contain a signed Form 9886 for at least one member of the household age 18 or over. ? 1 file where the tenant?s income was calculated correctly but had the wrong amount reported on the 50058, which would have decreased HAP rent by $11. ? 1 file where the prior year utility allowance schedule was used instead of the current year, however this had no effect on HAP rent. ? 1 file where there was no support that an inspection had been done for a new admission. ? 1 file that did not contain a tenancy addendum to support the contract rent and HAP rent for a tenant with a project-based voucher. ? 2 files where there was no support that an EIV report had been processed. In addition to the above, we noted the following during our new admissions testing ( new admissions tested): ? 3 files that did not contain a passed inspection completed prior to move-in. ? 1 file that did not contain a signed lease agreement or tenancy addendum. ? 1 file where the request for tenancy approval was not executed until the day after the voucher had expired. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: Errors were corrected in the tested files where corrections could be made. Meaning for example Form 9886 cannot be regenerated for this audit period but will be obtained during future annual recertification (also known as the personal declaration/application) periods. Adjustments will be made to the tenant accounts. Staff was informed to obtain Form 214 during all recertification re-examinations to ensure the required form is in the file. This way, if it was never obtained or if it was inadvertently purged, the file will always have a copy in the file for the review period. File Audit: A file audit (not a 100% audit) was completed for the Housing Choice Voucher Program. A procured third-party vendor performed this process. However, previous staff members did not make the file corrections. For months, there was only one staff member in the HCV Department. The department, at this time, is fully staffed. The current staff is making the file corrections as they come across various issues while moving the program/department forward. Of importance to note is the hire of a new Chief Operating Officer with over twenty (20) plus years of HCV experience who will oversee the Section 8 Department. We believe the new leadership, to include CEO and COO positions will provide the necessary oversight of the HCV program that will improve the overall performance of staff and the program. Quality Control Review: After completion of the file audit, the Housing Choice Voucher Program Manager and their supervisor will be responsible for documented monthly quality control reviews of 10% of files completed during the month. Effective Date: June 22, 2023 Contact Information Marcus Goodson, Interim Executive Director Sanford Housing Authority 1000 Carthage Street Sanford, North Carolina 27330 (919) 776-7655

Categories

HUD Housing Programs Eligibility Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 588928 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $3.94M
14.850 Public and Indian Housing $994,631
14.872 Public Housing Capital Fund $764,701
14.896 Family Self-Sufficiency Program $157,311
14.870 Resident Opportunity and Supportive Services - Service Coordinators $20,174