Corrective action plan:
• On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program
policies and procedures for training purposes. At each meeting, specific aspects of administering the
program are reviewed, along with the related HUD policies. Staff members are given the opportunity to ask
any questions on any procedures or policies they may not understand. Activities from the Nan McKay Rent
Calculation training are passed out to staff to complete individually. After staff completes the activity, the
answers are reviewed as a group. Other activities take place which involve the staff answering questions
regarding various case studies of situations that may occur in the daily activities of administering the HCV
Program.
• January 9th – 11th, all HCV and PBV Specialist received Combo HCV/LIPH Rent Calculation training with
HOTMA updates from Nan McKay and Associates.
• Review and update Administrative Plan/SOP with Policies and Procedures to ensure all staff is familiar
with policies and procedures.
• Staff restructuring
• In-service meetings with Compliance Specialist as staff challenges some write ups of deficiencies to
ensure that there are mutual understandings of policies.
• HCV/Occupancy Specialists have been instructed to triple check all certifications for accuracy to mitigate
the possibility for careless errors
PERSONS INVOLVED
HCV Case Management Staff
Asset Manager
RAD Project Based Voucher Community Manager
Compliance Specialist
Compliance Supervisor
HCV Program Director
Occupancy Specialist
MONITORING
The Compliance Supervisor and Specialist will continue to monitor files.
The Compliance Supervisor and Specialist will begin adding the CFR Regulation and or Administrative
Plan Policy and page number to each deficiency write-up to assist staff in understanding the error so that
staff will not make consistent errors.
The Compliance Supervisor will provide to staff recommendations for improvement.
It is hopeful that a greater number of participant files will be audited throughout the year for both the HCV
Program and for the PBV communities. On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program
policies and procedures for training purposes. During these meetings specific aspects of administering the
program are reviewed, along with the related HUD policies. Staff members are given the opportunity to
ask any questions on procedures or policies they may not understand. During many meetings, activities
from the Nan McKay Rent Calculation training are passed out to staff to complete individually. After staff
completes the activity, the answers are reviewed as a group. Staff also answers questions regarding
various case studies that may occur in the daily activities of administering the HCV Program. We also have
NRHA’s Compliance staff provide training to review common errors and to discuss any areas staff may
have that are gray with audited files. Staff has also gone through an intensive training on the common
errors per NRHA’s Compliance Department.
Quarterly Quality Control trainings are held with caseworkers lead by the NRHA Compliance Department to
address concerns and common errors. The Admission and Continued Occupancy Policies (ACOP) and
Administrative Plan policies and procedures are reviewed to ensure that all staff has a clear understanding
of the proper ways of calculating income, applying allowances, using proper payment standards, and
approvals of lease ups and completion of certifications.
A departmental quality control team was established to ensure there is consistency of policies and
procedures and that when new procedures are implemented the processes are properly documented and
disseminated to all staff.
A departmental quality control sub-team was formed after the audit to include the actual custodians of
program participant files comprised of:
1 Tax Credit PBV Property Manager
1 LIPH Property Manager
1 Compliance Specialist
1 Occupancy Specialist
1 Senior HCV Specialist
1 Tax Credit Administrative Assistant
NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for
accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to
audit files for the HCV Program to ensure that files are being processed properly; income calculated
correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely.
Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated
by the Compliance Department to ensure findings were corrected.
NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for
accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to
audit files for the HCV Program to ensure that files are being processed properly; income calculated
correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely.
Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated
by the Compliance Department to ensure findings were corrected. NRHA will continue to investigate the possibility of increasing the number of program participant files
reviewed by the Compliance Department.
NRHA has begun contract negotiations with a new software vendor. It is the feeling of the agency that
with a different software platform the errors being made will lessen as the information gathered to perform
rent calculations will be in a more automated form. It is anticipated that this will lessen staff time needed
to enter the information and thus allow for more time to be spent verifying accuracy of information. The
timeline for implementation is for the software to be live at the beginning of the 2026 fiscal year. This
over-riding strategy is to be done in conjunction with the steps outlined below to mitigate this situation.