Finding 238658 (2022-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-09-04

AI Summary

  • Core Issue: Significant errors found in 95 out of 245 Housing Choice Voucher tenant files, including income miscalculations and incomplete certifications.
  • Impacted Requirements: Noncompliance with federal regulations and Housing Authority guidelines regarding tenant file documentation and recertification processes.
  • Recommended Follow-Up: Conduct a comprehensive audit of tenant files and enhance monitoring and training for occupancy specialists to reduce errors.

Finding Text

Finding 2022-001 ? Housing Choice Voucher Tenant Files ? Eligibility ? Internal Control over Tenant Files ? Noncompliance and Significant Deficiency Housing Choice Voucher Program CFDA #14.871 Condition & Cause: Our review of two hundred forty-five (245) HCV tenant files revealed that there were ninety-five (95) files containing errors of noncompliance noted during the audit. Of these, there were nineteen (19) income errors. This represents a 7.76% sample deviation rate across the total population. The income errors consisted of failure to calculate tenant income correctly, failure to have a third party verify tenant income correctly, and improper year-to-date analyses. We noted seventy-four (74) files that had certifications not completed within 12 months of the prior annual. There was one (1) file in which the tenant should have been removed from the program but was not. We also found one (1) file in which the tenant was not given the correct deductions. Lastly, we found five (5) files that contained forged documents, although these files had additional errors that fall under the categories above. Old recertification packets that had been filled out by the tenant were photocopied and brought forward as support for current recertifications. Dates were changed for the photocopies to give the impression that the documents had been signed at the time of the current certification. During the audit, it was noted that although COVID procedures approved by HUD have expired, the Authority is still experiencing difficulties trying to get tenants to return recertification documentation. Criteria: The Code of Federal regulations, the Housing Authority?s Administrative plan, and specific HUD guidelines in documenting and maintaining the Housing Choice Voucher tenant files. Recommendation: We recommend that the Agency conduct a thorough tenant file audit of existing tenants in the HCV program to determine whether there are any misstatements of rental income. We also recommend that the Agency increase their monitoring and review of the HCV program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Our experience with agencies that increase monitoring and review of the files is that there are dramatically decreased error rates. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

Finding 2022-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Significant Deficiency Corrective Action Plan: GHA will implement the following immediate and on-going actions to correct internal control over participant files in the Housing Choice Voucher program: Immediate Response: GHA is guided by seven core values. The first of which is Integrity. Upon discovery of forged documents, in March 2023 it was clearly communicated and reiterated that any actions, such as alternation, falsification, or fabrication is unacceptable and the appropriate disciplinary would be taken. A prompt and thorough investigation resulted in a team member being terminated for forging documents and a change is senior leadership. A third-party consultant was brought in immediately to complete an assessment and review of the voucher programs internal process to provide immediate process improvement along with reviewing an additional sample set of participant files. Ongoing Response: GHA will improve internal controls in the area of file review and quality control and assurance by completing multiple examinations of applicants/program participants calculations at initial move- in, interim, and re-examination anniversary. In addition to the two-prong reviews being completed by team members, a third-party compliance company may be used to review all initials, and up to twenty-five percent (25%) of all interim and re-examination of program participants' files. Internal/external training will be provided to each team member involved with the determination of rent and maintaining tenant files, as well as programmatic eligibility and administration of the housing choice voucher program in 2023. Voucher Administration leadership will continue to work closely with the Compliance Department to ensure that GHA's program files are compliant with all federal regulations, rules, HUD guidelines as well as GHA's policy and procedures. Anticipated Completion Date: The above plans will be implemented immediately and will be continuously monitored. We anticipate a completion date of December 2023. Responsible Person: Meredith Daye, Chief Operating Officer

Categories

HUD Housing Programs Subrecipient Monitoring Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 815100 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $28.40M
14.850 Public and Indian Housing $2.87M
14.872 Public Housing Capital Fund $1.65M
14.879 Mainstream Vouchers $1.01M
14.247 Self-Help Homeownership Opportunity Program $413,214
14.267 Continuum of Care Program $327,240
14.896 Family Self-Sufficiency Program $282,581
14.241 Housing Opportunities for Persons with Aids $133,606
14.870 Resident Opportunity and Supportive Services - Service Coordinators $83,640
14.169 Housing Counseling Assistance Program $36,854
14.871 Ehv - Section 8 Housing Choice Vouchers $36,255