Finding Text
Criteria: 24 CFR Section 982 requires recipients of Section 8 Housing Choice Vouchers to submit data on monthly leasing activities and costs for the program via mandatory Public Housing Authority (PHA) reporting through the Voucher Management System (VMS). The Department of Housing and Urban Development (HUD) reviews VMS data and uses the data for a variety of major functions, including budget formulation, utilization analysis and funding allocations.
Condition: During the current year, the City underwent a monitoring review by the grantor related to the VMS data submitted by the City to HUD for the City’s Section 8 Housing Choice Voucher Program (Program) for the time period of December 1, 2021 through November 30, 2022. The purpose of the review was to validate the Unit Months Leased (UML) and related Housing Assistance Payment (HAP) expenses certified as accurate by the PHA. The grantor issued a letter dated March 6, 2023 detailing the results of the review.
The monitoring review results included one finding and three concerns:
Finding 1: Multiple HAP and unit months leased (UML) categories could not be validated, adversely affecting validation of total HAP and total UML.
Concern 1: The portable vouchers administered UML and HAP could not be validated.
Concern 2: Vouchers issued but not under HAP contract on the last day of the month could not be validated.
Concern 3: The PHA did not report the number of project-based vouchers (PBVs) under an agreement to enter into a HAP contract and not under a HAP contract.
Concern 4: The number of PBVs under HAP contract and leased/not leased; and the total PBV HAP expenses could not be validated.
Effect: The Housing Authority is not in compliance with the requirements set forth by 24 CFR Section 982 regarding VMS reporting.
Cause: The Housing Authority’s re-inspection delays discussed above were due to understaffing at the Housing Authority during fiscal years 2022 and 2023. Furthermore, the Housing Authority converted its Housing software during fiscal year 2022. During the data migration process, certain leasing and contract documents did not transfer into the new Housing software and the Housing Authority no longer had access to certain leasing and contract documents.
Recommendation: Although the City responded to the findings in its April 6, 2023 letter to the grantor with corrective action plans, the City should revise its policies and procedures, where applicable, to ensure that all VMS reporting is in compliance with the grant requirements and CFR. In addition, the City should continue to work with HUD to ensure compliance with all goals identified in the corrective action plan provided to HUD.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.