Finding 19839 (2022-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-06-28

AI Summary

  • Core Issue: The Authority has significant compliance failures in tenant eligibility and rent calculations for the Housing Voucher program, with 56 out of 60 files tested showing errors.
  • Impacted Requirements: Key requirements include proper documentation (like HUD-50058 and Section 214 Declaration), annual reviews, and third-party income verification, which were not met.
  • Recommended Follow-Up: Assign a dedicated staff member to monthly review a sample of recertified tenant files to ensure compliance and address identified deficiencies.

Finding Text

Finding 2022 ? 001 ? Eligibility Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Award Period: October 1, 2021 to September 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Other Matters Criteria or specific requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant?s eligibility and also determine the tenants? portion of rent and the Authority?s portion of the rent. Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). (3) Determine income eligibility and calculate the tenant?s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 11 Where the Authority was unable to provide a tenant file to review Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Finding 2022 ? 001 ? Eligibility Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 46 Where the file was missing the Section 214 Declaration for family members 46 Where the income, assets, or expenses calculated on the 50058 was not supported 46 Where the Authority did not review the information on an annual basis 38 Where the file was missing the HUD-9886 authorization form 37 Where the file was missing the Authority general release form 23 Where the HAP information from the 50058 did not agree to support 23 Where the HAP Contract could not be verified to supporting documents 45 Where the Housing Choice Voucher?s tenant file was missing the preparer checklist that is utilized as an internal control to ensure all required elements are in the tenant file Questioned costs: Undeterminable. Context: Out of 60 housing choice vouchers and mainstream tenant files tested, 56 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements and the calculation of the rent and verification of the tenant?s income. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, and 2021-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Eligibility 2022-001 ? Eligibility Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, and increased compliance and accountability. The PBCHA will continue to utilize all available resources to recruit, retain and train HCVP staff on the HCV program guidelines, to include training to determine what is included and excluded from annual income, how to identify and calculate assets, correctly calculate adjusted income by applying the HUD defined allowances and expenses, recognize the requirements for verification of income, allowances, and expenses and calculate total tenant payment and housing assistance payment (HAP). The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiencies will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Board of Commissioners Paul Dumars, Chairman Phyllis Choy, Vice Chair Digna Mejia Charlie Fetscher CEO and Executive Director Carol Jones-Gilbert 3432 West 45th Street West Palm Beach, Florida 33407 Office: (561) 684-2160 ext. 104 Mobile: (561) 628-9387 Fax: (561) 455-9965 Name(s) of the contact person(s) responsible for corrective action: Tyler Rasmussen, Carol Jones- Gilbert

Categories

HUD Housing Programs Subrecipient Monitoring Eligibility Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 19840 2022-002
    Material Weakness Repeat
  • 19841 2022-003
    Material Weakness Repeat
  • 19842 2022-004
    Material Weakness Repeat
  • 19843 2022-005
    Significant Deficiency
  • 19844 2022-001
    Material Weakness Repeat
  • 19845 2022-002
    Material Weakness Repeat
  • 19846 2022-003
    Material Weakness Repeat
  • 19847 2022-004
    Material Weakness Repeat
  • 19848 2022-005
    Significant Deficiency
  • 596281 2022-001
    Material Weakness Repeat
  • 596282 2022-002
    Material Weakness Repeat
  • 596283 2022-003
    Material Weakness Repeat
  • 596284 2022-004
    Material Weakness Repeat
  • 596285 2022-005
    Significant Deficiency
  • 596286 2022-001
    Material Weakness Repeat
  • 596287 2022-002
    Material Weakness Repeat
  • 596288 2022-003
    Material Weakness Repeat
  • 596289 2022-004
    Material Weakness Repeat
  • 596290 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $30.29M
14.879 Mainstream Vouchers $3.05M
14.241 Housing Opportunities for Persons with Aids $2.92M
14.850 Public and Indian Housing $1.54M
14.872 Public Housing Capital Fund $1.49M
14.871 Emergency Housing Vouchers $570,541
14.871 Covid-19 Hcv Cares Act Funding $360,476
14.895 Jobs-Plus Pilot Initiative $241,191
14.850 Covid-19 Public Housing Cares Act Funding $129,791
14.896 Family Self-Sufficiency Program $107,770
14.870 Resident Opportunity and Supportive Services - Service Coordinators $43,974