Finding 387660 (2023-002)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299738
Auditor: Rbt CPAS

AI Summary

  • Core Issue: Missing documentation in tenant files, including the HUD-9886 and EIV forms, raises compliance concerns.
  • Impacted Requirements: The Authority must adhere to federal regulations and maintain proper internal controls for eligibility verification.
  • Recommended Follow-Up: Implement a checklist for Occupancy Representatives during recertification to ensure all compliance requirements are documented and verified.

Finding Text

2023-002 – Eligibility U.S. Department of Housing and Urban Development 14.850 – Public and Indian Housing Condition: During review of the Housing Choice Voucher program, RBT noted that two tenant files were missing the HUD-9886 form and one tenant file was missing the income verification (EIV) form. RBT also noted that the Authority was not appropriately documenting and maintaining documentation of the controls over Eligibility. Criteria: As a condition of receiving federal awards, the PHA agrees to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal controls to provide reasonable assurance of compliance with these requirements. As a condition of continued occupancy, PHAs must require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility. Cause: The Authority does not have a central, uniform location to document the controls in place over Eligibility. Effect: Potential noncompliance if a control is missed. Questioned Costs: None identified. Perspective: Out of 25 tenant files reviewed, two were missing the HUD-9886 form, and one was missing the EIV form. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the Authority establish a checklist for the Occupancy Representatives to use during the recertification process to ensure all compliance requirements are met. The checklist should be signed or initialed by the representative and maintained in the tenant’s file. This checklist will serve as documentation that all compliance requirements were verified for the tenant. Auditee’s Response: See corrective action plan.

Corrective Action Plan

Finding 2023-002 Eligibility Auditee's Response and Planned Corrective Action The Authority has had staff and consultant turnover during the 2022 audit period. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic have resulted in delayed or nonexistent response from tenants regarding obtaining the necessary documentation for eligibility requirements. The Authority has evidentiary documentation supporting their attempts to obtain the required documents from the tenants, including certified letters. The courts suspended evictions during the eviction moratorium that resulted from the COVID-19 pandemic, which includes evictions for nonpayment and noncompliance. The Authority has been working with legal counsel on these matters and continues to pursue this vigorously. The Authority's staff and consultants have been diligently working to implement improvements to the administrative systems related to recertifications. Additionally, the Authority has put in place a checklist for occupancy documents that are reviewed during recertification and when processing new tenants that must have annotations, check mark, that confirm that all required papers are in compliance and signed where appropriate. This check list will have at least one redundant review by the Authority's directors or designee. Planned Implementation Date of Corrective Action: March 2024 Person Responsible for Corrective Action: Keith Burrell, Executive Director

Categories

HUD Housing Programs Eligibility Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 964102 2023-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 Public and Indian Housing $742,459
14.872 Public Housing Capital Fund $363,784