Finding 374343 (2023-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-07

AI Summary

  • Core Issue: Thirteen annual recertifications were late, one was missing, and one income was miscalculated, indicating a significant compliance deficiency.
  • Impacted Requirements: Noncompliance with federal regulations and internal guidelines for maintaining tenant files.
  • Recommended Follow-Up: Complete overdue recertifications and enhance monitoring and training for staff to improve compliance.

Finding Text

Finding 2023-001 – Moving To Work Demonstration Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Moving To Work Demonstration - subsidy ALN 14.881 Condition & Cause: Our review of two hundred (200) Moving To Work tenant files revealed that there were thirteen (13) annual recertifications completed late, one (1) annual recertification that was not completed, and one (1) miscalculation of annual income, which represents 7.5% of the total files examined. We noted that the Agency experienced difficulty in hiring and retaining staff and operated with several employee vacancies throughout the fiscal year. Based upon this control deficiency encountered with our sample, we believe the Housing Authority has a significant deficiency in this area of compliance. Criteria: The Code of Federal regulations, the Housing Authority’s ACOP, Admin Plan, MTW Plan, and specific HUD guidelines in documenting and maintaining the Public Housing and Housing Choice Voucher tenant files. Recommendation: We recommend that the Agency identify the annual recertifications that are past or near due and complete these reexaminations. We also recommend that the Agency increase their monitoring and review of the Moving To Work files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. 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

Re: 2023-01 Audit Finding/Plan of Action The Lexington Housing Authority (LHA) proposes this corrective plan of action to address the late recertifications (13) and annual recertification (1) from the audit conducted by Rector, Reeder & Lofton PC, onsite at LHA September 25-29, 2023. ADDRESSING STAFFING Securing qualified candidates to fill Housing Management Specialist (HMS) positions throughout 2020, 2021 and 2022 was challenging for LHA. In some instances, positions were vacant for up to 12 months before they were filled. LHA will do the following to address staffing: • Seek to fill HMS positions within forty-five (45) days of the position going vacant. • Advertise to hire two full-time HMS positions for the two management teams with the most units in their management portfolio. • Continue to advertise open positions online, on social media and in the local newspaper. • Offer incentive bonus up to $1,500 to newly hired HMS, paying $750 to new hires after six month of employment and an additional $750 after 12 months of employment. • Over-time will be allowed on an as-needed basis to complete and process certifications. CERTIFICATION PROCEDURES Further, LHA housing management staff will adhere to the following procedures to facilitate timely completion of annual certifications. - HMS staff will continue utilize in-person interviews and mail (via USPS and email) to complete needed documentation for annual certifications. - All housing management staff may utilize electronic signature to attain required signatures when necessary. - The first day of each month housing managers will run the certification audit report to be shared with the Chief Operating Officer to monitor the status of in-progress and upcoming certifications. - July 1, 2023, LHA implemented quality control (QC) of public housing files to be conducted by a newly created compliance position. LHA' s compliance coordinator will complete 229 (25%) QC reviews of public housing files during FY2024 (July 1, 2023 - June 30, 2024). - At least once monthly on a rotating basis housing management staff from all offices will convene at a selected housing management office to complete and process certifications. This schedule will continue until all offices are up to date on certifications. LHA staff will apply these procedures as outlined to mitigate this finding to ensure compliance and proper documentation of future certifications. Contact Person: Andrea Wilson, Chief Operating Officer Anticipated Completion Date: June 30, 2024

Categories

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

Other Findings in this Audit

  • 950785 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $23.99M
14.879 Mainstream Vouchers $1.00M
14.871 Section 8 Housing Choice Vouchers $872,910
14.870 Resident Opportunity and Supportive Services - Service Coordinators $175,448
14.238 Shelter Plus Care $167,319
14.850 Public and Indian Housing $33,705