Finding 36570 (2022-004)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-07-25

AI Summary

  • Core Issue: Significant compliance failures in tenant files, including missing signatures, unverified income, and improper lease documentation.
  • Impacted Requirements: Key regulations regarding lease agreements, rent reasonableness, and tenant documentation were not followed, leading to potential questioned costs of $15,556.00.
  • Recommended Follow-Up: Springfield MHA should implement corrective actions, including ensuring all required signatures and documentation are obtained before subsidy payments, and verifying annual income prior to tenant occupancy.

Finding Text

Tenant Files Condition: Housing Choice Vouchers Move-ins: 1. In two (2) instances out of ten (10) tenant files tested, the date on the lease agreement did not agreement to the effective move-in date. 2. In six (6) instances out of ten (10) tenant files tested, the lease agreement was not maintained in the tenant's file. 3. In one (1) instance out of ten (10) tenant files tested, the lease agreement did not indicate the initial lease date or the rent amount. 4. In ten (10) instances out of ten (10) tenant files tested, the "Lease Addendum" - Violence Against Women and Justice Department Reauthorization Act of 2005, was not signed by the Landlord. 5. In four (4) instances out of ten (10) tenant files tested, the HAP Contract was not signed by the Owner. 6. In three (3) instances out of ten (10) tenant files tested, the Tenancy Addendum was not maintained in the tenant's file. 7. In two (2) instances out of ten (10) tenant files tested, the Voucher expired prior to the issuance of the Request for Tenancy Approval. 8. In one (1) instance out of ten (10) tenant files tested, the "Reasonableness Valuation" form was not maintained in the tenant's file. 9. In one (1) instance out of ten (10) tenant files tested, the "Addition to Landlord and Tenant Lease" was not maintained in the tenant's file. Recertification: 1. In fifteen (15) instances out of twenty-five (25) tenant files selected for testing, that the notification of corrective actions was indicated to the Landlord, without indicating the number of days allowed for the correction. 2. In one (1) instance out of twenty-five (25) tenant files selected for testing, the annual recertification was not performed, during the 2022 fiscal year. 3. In one (1) instance out of twenty-four (24) tenant files selected for testing, the Authorization for the Release of Information (Form HUD-9886), was not dated by the tenant. 4. In two (2) instances out of twenty-four (24) tenant files selected for testing, the annual income was not verified in accordance to ?Part III: Verifying Income and Assets ? 7-III.A. Earned Income?. 5. In four (4) instances out of twenty-four (24) tenant files selected for testing, the inspection report maintained in the tenant's file, indicated that the inspection failed and/or was inconclusive; therefore, no Pass inspection was obtained, prior to the tenant?s effective move-in date. Move-outs: 1. In four (4) out of five (5) tenant files, selected for test, there was no notice sent to the landlord, indicating the termination date. Criteria: 1. Lease agreement must be signed by the tenant and landlord, prior to the PHA making a subsidy payment to the landlord. 2. Rent reasonableness must be determined and documented on a case-by-case basis that the approved rent is reasonable in comparison to rent for other comparable unassisted units in the market. The PHA will not approve a lease until the PHA determines that the initial rent to owner is a reasonable rent. 3. The Lease Addendum ? Violence Against Women and Justice Department Reauthorization Act of 2005 form, must be signed by the landlord and tenant, prior to the PHA making a subsidy payment to the landlord. 4. Passed inspection must be obtained, prior to the tenant occupying the housing unit. In addition, deficiencies must be reinspected within 30 days. 5. Once a family?s housing choice voucher term expires, the family is no longer eligible to search for housing under the program. 6. For verification of annual income, family must provide originals of up to the four most concurrent pay stubs. SS/SSI benefits, requires the PHA to request a current SSA benefit verification letter from each family member that receives social security benefits. 7. The HAP contract represents a written agreement between the PHA and the owner of the dwelling unit occupied by a HCV assisted family. 8. Authorization for the release of information form, must be signed and dated by the tenant, prior to the PHA requesting income information from the sources listed on the form. Effect: Potential questioned cost of $15,556.00. Context: Tenant files tested consisted of move-ins, recertifications and move-outs. Population Size Number: 899 tenant files Dollar Amount: $3,667,783. Sample Number: 40 tenant files tested Dollar Amount: $163,194. Items Not in Compliance Number: 15 non-compliance findings Dollar Amount: $15,556. Questioned Costs There were potential questioned costs of $15,556.00. Cause: Oversight by Management. Recommendation: In order to be in compliance with guidelines established by the Department of Housing and Urban Development, I recommend that Springfield Metropolitan Housing Authority 1) determines the rent reasonableness, prior to making a subsidy payment to the landlord; 2)obtain the tenant and landlord signature, prior to making a subsidy payment to the landlord; 3) obtain the lease-addendum ? violence against women form, prior to making a subsidy payment to the landlord; 4) The HAP should be signed by the tenant and the owner, prior to the tenant occupying the housing unit; 5) obtain the tenant?s signature and date on the authorization for release of information, prior to requesting household income information, and 6) Annual income should be verified by the PHA, prior to the tenant occupying the housing unit. By performing these procedures, the risk of incurring questioned costs will be significantly reduced. Views of Responsible Officials and Planned Corrective Actions: Springfield MHA will review all files from this audit to make necessary corrections. SMHA will review and update policy to ensure all program requirements are met.

Corrective Action Plan

4. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation d. Finding 2022-002. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Tenant Files Housing Choice Vouchers Move-ins: 1. In two (2) instances out of ten (10) tenant files tested, the date on the lease agreement did not agreement to the effective move-in date. 2. In six (6) instances out of ten (10) tenant files tested, the lease agreement was not maintained in the tenant's file. 3. In one (1) instance out of ten (10) tenant files tested, the lease agreement did not indicate the initial lease date or the rent amount. 4. In ten (10) instances out of ten (10) tenant files tested, the "Lease Addendum" - Violence Against Women and Justice Department Reauthorization Act of 2005, was not signed by the Landlord. 5. In four (4) instances out of ten (10) tenant files tested, the HAP Contract was not signed by the Owner. Tenant Files (continued) Move-Ins: 6. In three (3) instances out of ten (10) tenant files tested, the Tenancy Addendum was not maintained in the tenant's file. 7. In two (2) instances out of ten (10) tenant files tested, the Voucher expired prior to the issuance of the Request for Tenancy Approval. 8. In one (1) instance out of ten (10) tenant files tested, the "Reasonableness Valuation" form was not maintained in the tenant's file. 9. In one (1) instance out of ten (10) tenant files tested, the "Addition to Landlord and Tenant Lease" was not maintained in the tenant's file. Recertification: 1. In fifteen (15) instances out of twenty-five (25) tenant files selected for testing, that the notification of corrective actions was indicated to the Landlord, without indicating the number of days allowed for the correction. 2. In one (1) instance out of twenty-five (25) tenant files selected for testing, the annual recertification was not performed, during the 2022 fiscal year. 3. In one (1) instance out of twenty-four (24) tenant files selected for testing, the Authorization for the Release of Information (Form HUD-9886), was not dated by the tenant. Recertification: (continued) 4. In two (2) instances out of twenty-four (24) tenant files selected for testing, the annual income was not verified in accordance to ?Part III: Verifying Income and Assets ? 7-III.A. Earned Income?. 5. In four (4) instances out of twenty-four (24) tenant files selected for testing, the inspection report maintained in the tenant's file, indicated that the inspection failed and/or was inconclusive; therefore, no Pass inspection was obtained, prior to the tenant?s effective move-in date. Move-outs: 1. In four (4) out of five (5) tenant files, selected for test, there was no notice sent to the landlord, indicating the termination date. (1) Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor?s recommendation that Springfield Metropolitan Housing Authority should 1) determines the rent reasonableness, prior to making a subsidy payment to the landlord; 2)obtain the tenant and landlord signature, prior to making a subsidy payment to the landlord; 3) obtain the lease-addendum ? violence against women form, prior to making a subsidy payment to the landlord; 4) The HAP should be signed by the tenant and the owner, prior to the tenant occupying the housing unit; 5) obtain the tenant?s signature and date on the authorization for release of information, prior to requesting household income information, and 6) Annual income should be verified by the PHA, prior to the tenant occupying the housing unit. By performing these procedures, the risk of incurring questioned costs will be significantly reduced. (2) Actions Taken on the Finding. Springfield MHA will review all files from this audit to make necessary corrections. SMHA will review and update policy to ensure all program requirements are met.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 36567 2022-001
    Significant Deficiency
  • 36568 2022-002
    Significant Deficiency
  • 36569 2022-003
    Significant Deficiency
  • 613009 2022-001
    Significant Deficiency
  • 613010 2022-002
    Significant Deficiency
  • 613011 2022-003
    Significant Deficiency
  • 613012 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $4.34M
14.850 Public and Indian Housing $3.04M
14.872 Public Housing Capital Fund $662,750
14.879 Mainstream Vouchers $154,203
14.238 Shelter Plus Care $113,555
14.870 Resident Opportunity and Supportive Services - Service Coordinators $59,864
14.896 Family Self-Sufficiency Program $19,230