Finding Text
Criteria: The Uniform Guidance requires that HALC maintain proper documentation to demonstrate compliance with the requirements of the program. Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements: ? Reporting - SEMAP certification. During our testing over compliance related to the Authority?s SEMAP certification, HALC was unable to provide the auditors with supporting documentation over the submitted certified performance indicators during the year. ? Special Tests: o Waiting list o Reasonable rent o Utility allowance schedule o Housing quality standards enforcement During our testing over the waiting list, auditor noted 3 of the 14 selections tested were admitted into the program but no support was provided indicating the participants top of the list letter agreed to the monthly waiting list report and in proper order with other applicants on the monthly waiting list report. During our testing over reasonable rent, HALC was unable to provide supporting documentation over all 40 selections that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required. During our testing over the utility allowance schedule, HALC was unable to provide support the utility allowance schedule was maintained for an up-to-date utility allowance schedule as the Authority must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. During our testing over housing quality standards enforcement, auditor noted 2 of the 5 selections tested, the participant received a 4-month extension at the time of inspection by the contracted inspector and HALC management was unable to provide documentation to support the reason why an extension was granted at the time of failure. Further, auditor noted no notice of deficiency in the participant?s file had been sent to the property owner. Auditor noted in 1 of the 5 selections tested, the documents retained in the participant file were unclear as to when the unit passed inspection. There was contradicting dates and information scattered throughout the file. Auditor noted in 1 of the 5 selections tested, the participants file had no notice of deficiency for the inspection failure on 8/30/2022, as well as no other indication of follow-up by HALC to enforce the family obligation to correct the failure. Auditor noted in 1 of the 5 selections tested, a notice of deficiency for a 24-hour life threatening deficiency dated 6/15/2022, but no support documenting the repair had been completed within the 24-hour required timeframe. Auditor further noted the file had a second failure notice sent on 8/4/2022 was responded to with a self-certification form dated 8/10/2022 by the landlord and tenant stating the repair had been completed on 6/15/2022. The participant file did not show a notice of abatement for failure to remedy the 24-hour repair deficiency as of 6/16/2022. Cause: The Authority experienced a high degree of personnel turnover from 2020 through 2022. HALC?s Executive Director who had many years of HUD experience retired during 2022 and personally performed several duties related to the Section 8 program, as well as the Authority experiencing several housing assistant staff turnovers annually. Effect: The HAP payment related to the HQS enforcement participant could be disallowed. The known HAP payment for the two-month period was $2,050 and the sample size was 20% of the total population. The amount does not rise to a questioned cost level. Identification of Repeat Finding: Not a repeat finding. Recommendation: The Authority should: ? Strengthen the training available to staff that are responsible for determining and documenting compliance with each of the compliance requirements. ? Strengthen the review process of tenant files by management so that errors will be identified prior to payments being made to landlords on the tenant?s behalf. ? Train additional members of management and staff to perform and back-up the compliance duties related to the Section 8 program. Views of Responsible Officials and Planned Corrective Action Plan: There is no disagreement with these findings. Management has taken steps to remedy the errors, such as hiring a third-party vendor to assist in the calculation and determination of utility allowances, cross-train current staff to perform other duties related to the Section 8 program and attend additional Section 8 trainings.