Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV
Recommendation: We recommend that the Authority review their internal controls over the eligibility requirements to ensure all documentation is maintained at the time of recertification. We recommend the Authority review their internal controls over the HAP process to ensure the correct amounts are paid each month. We recommend the Authority review their process for uploading data to PIC to ensure each recertification gets submitted.
Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
Action taken in response to finding: The Authority has begun the assessment, development and implementation of several internal controls to address recertification documentation, HAP processes, and PIC data submission to ensure compliance with Federal regulations.
The Authority will develop and implement a quality control process on or before June 30, 2024, to ensure all documentation is maintained, signed and dated by all required parties at the time of certification. Currently, the Authority has developed a checklist system for each step of the recertification process. The checklist includes each step of the recertification process, along with due dates, and responsible entities. While not a Federal Requirement, the Authority did establish the discretionary policy to require housing specialists sign and date the Housing Information Forms. This policy was implemented after this audit finding and would not have been a requirement of the one file reviewed by the audit team. However, this step is included in the checklist process.
The Authority is actively working to modify the electronic documentation and record retention system and process. Planned implementation of new electronic documentation and record retention processes is contingent on system updates managed by third party venders, however new written internal procedures are under development.
The Authority will develop and implement a quality control process for the HAP process on or before June 30, 2024. This will include procedures for Program Compliance Officers (PCOs) and HCVP’s Accounting Team to work closely and coordinate to ensure each responsible person fully understands their roles and responsibilities. The Authority will implement monthly reviews of HAP payments, by the Housing Choice Voucher Program Compliance Manager. The Authority PCOs and/or accounting staff will follow the procedures for correcting any issues identified during the reviews.
Over the past year, the Authority has created a System and Reporting Team that is now responsible for timely PIC submissions and addressing discrepancies and/or errors in the PIC and/or EIV system. By having a dedicated team, the Authority now exceeds the HUD requirement of submitting PIC data within 60 days of the effective date of any action. The Authority submits PIC monthly, performs monthly reviews of PIC data, and ensures staff addresses all fatal errors. In addition to these processes, the System and Reporting Team receives one on one training to address specific and challenging errors and discrepancies.
Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives
Planned completion date for corrective action plan: June 30, 2024