Finding 386895 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-03-28
Audit: 299209
Organization: Pittsfield Housing Authority (RI)
Auditor: Marcum LLP

AI Summary

  • Core Issue: The Authority failed to conduct necessary rent reasonableness assessments, violating HUD requirements.
  • Impacted Requirements: The PHA must determine and redetermine reasonable rent before lease approval and rent increases.
  • Recommended Follow-Up: Implement a recertification checklist to ensure all required documentation is collected for tenant files.

Finding Text

2023-002 – SPECIAL TESTS AND PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871 – Housing Voucher Cluster CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507). CONDITION The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned Costs - $4,337,214. CONTEXT We selected a sample of 40 from a population of 580. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-002. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.

Corrective Action Plan

Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. PHA began conducting reasonableness determinations utilizing the Rent Reasonableness software, beginning March 2023. Rent reasonableness determinations are now being made for all participants prior to initial HAP contract execution and in conjunction with any requested rent increases. Continuing compliance will be internally reviewed during a July 2024 SEMAP QC review.

Categories

Questioned Costs HUD Housing Programs Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 386894 2023-001
    Material Weakness Repeat
  • 386896 2023-003
    Material Weakness Repeat
  • 386897 2023-004
    Material Weakness
  • 963336 2023-001
    Material Weakness Repeat
  • 963337 2023-002
    Material Weakness Repeat
  • 963338 2023-003
    Material Weakness Repeat
  • 963339 2023-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $4.66M
14.850 Public and Indian Housing $825,861
14.872 Public Housing Capital Fund $114,416