Finding 37883 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2022-12-28

AI Summary

  • Core Issue: The Public Housing Authority (PHA) failed to conduct required annual inspections and obtain owner certifications for some units, leading to non-compliance with Housing Quality Standards (HQS).
  • Impacted Requirements: Compliance with HUD's Notice PIH 2021-14(HA) regarding HQS inspections and owner certifications was not met, resulting in a significant deficiency in internal controls.
  • Recommended Follow-Up: The PHA should establish and enforce internal control procedures to ensure compliance with federal regulations and improve oversight of HQS inspections.

Finding Text

Finding 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? N. Special Tests and Provisions ? Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. On May 4, 2021, HUD issued Notice PIH 2021-14(HA). In this notice, HUD recognized the unprecedented challenge the COVID-19 pandemic poses to PHAs in carrying out the most essential of their HCV program administrative responsibilities. The notice allowed for the Authority to rely on the owner's certification that the owner has no reasonable basis to have knowledge that life-threatening conditions exist in the unit or units in questions. At minimum, the PHA must require the owner?s certification. However, the PHA may add other requirements or conditions in addition to the owner?s certification, but is not required to do so. The PHA is required to conduct an HQS inspection on the unit as soon as reasonably possible but no later than June 30, 2022. Condition: Based upon inspection of the Authority?s files and on discussion with management there were units that did not have annual inspections or owner?s certifications performed during the audit period. Context: Of a sample size of sixty-five (65) tenant files, the following information was unavailable for examination at the time of audit: ? Annual inspection report or owner's certification documentation was missing in two (2) files. Our sample size is statistically valid. Known Questioned Costs: $41,038 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance with Notice PIH 2021-14(HA). Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. deficiencies in the Section 8 Housing Choice Vouchers Program and has implemented internal control procedures in 2022 that will ensure compliance of federal regulations.

Corrective Action Plan

Corrective Action Plan For the year ended March 31, 2022 U.S. Department of Housing and Urban Development: The Housing Authority of the County of Contra Costa respectfully submits the following corrective action plan for the year ended March 31, 2022. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the March 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings ? Federal Award Program Audit Finding 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? N. Special Tests and Provisions ? Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Findings ? Federal Award Program Audit (continued) Finding 2022-001 (continued) Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. On May 4, 2021, HUD issued Notice PIH 2021-14(HA). In this notice, HUD recognized the unprecedented challenge the COVID-19 pandemic poses to PHAs in carrying out the most essential of their HCV program administrative responsibilities. The notice allowed for the Authority to rely on the owner's certification that the owner has no reasonable basis to have knowledge that life-threatening conditions exist in the unit or units in questions. At minimum, the PHA must require the owner?s certification. However, the PHA may add other requirements or conditions in addition to the owner?s certification, but is not required to do so. The PHA is required to conduct an HQS inspection on the unit as soon as reasonably possible but no later than June 30, 2022. Condition: Based upon inspection of the Authority?s files and on discussion with management there were units that did not have annual inspections or owner?s certifications performed during the audit period. Context: Of a sample size of sixty-five (65) tenant files, the following information was unavailable for examination at the time of audit: ? Annual inspection report or owner?s certification was missing in two (2) files Our sample size is statistically valid. Known Questioned Costs: $41,038 Cause: There is significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies in the Section 8 Housing Choice Vouchers Program and has implemented internal control procedures in 2022 that will ensure compliance of federal regulations. Those controls consist of the weekly monitoring of two reports generated by the agency business software which identify subsidized units missed by the inspection scheduler. Ingrid Layne, the Director of Assisted Housing will be responsible to implement this corrective action by March 31, 2023. Schedule of Prior Year Federal Audit Findings There were no findings or questioned costs in the prior year. If the U.S. Department of Housing and Urban Development has any questions regarding this plan, please call Ingrid Layne, the Director of Assisted Housing at (925) 957-7010. Sincerely yours, Ingrid Layne, Director of Assisted Housing

Categories

Questioned Costs HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 614325 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $182.60M
14.850 Public and Indian Housing $7.23M
14.267 Continuum of Care Program $6.80M
14.872 Public Housing Capital Fund $3.03M
14.879 Mainstream Vouchers $2.70M
14.896 Family Self-Sufficiency Program $180,477