Finding 401548 (2023-005)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-06-24

AI Summary

  • Core Issue: The Authority lacks adequate internal controls to ensure compliance with eligibility requirements for the Housing Voucher program, leading to material noncompliance.
  • Impacted Requirements: Key compliance areas include tenant income verification, annual reviews, and correct calculations of tenant rent and housing assistance payments.
  • Recommended Follow-Up: Management should enhance monitoring of recertifications, designate a reviewer for monthly file samples, and ensure compliance standards are consistently met.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 Federal Award Identification Number and Year: LA003, 2023 Award Period: 10/1/22-9/30/23 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (3) Determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5, Subpart F (24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions – Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR sections 960.253, 960.257, and 960.259). (a) The Rental Demonstration program prohibits PHAs from rescreening or requiring a tenant recertification due solely to a RAD conversion. However, this requirement does not eliminate the normally scheduled recertification (normally annually). Recertifications required to be performed as part of the normal tenant recertification process that occur after the RAD conversion, but before the end of the calendar year, will be conducted under the selected conversion program (PBV or PBRA) and not Public Housing. These recertifications are to be conducted to ensure that tenant payments are appropriate under the new program. Any testing that results in an audit finding should be a finding of the PBV or PBRA program and not of the public housing program. (b) Eligible beneficiaries are lower income families, which include citizens or eligible immigrants. “Families” include, but are not limited to, (1) a family with or without children; (2) an elderly family (head, spouse, or sole member 62 years or older); (3) near-elderly family (head, spouse, or sole member 50 years old but less than 62 years old); (4) a disabled family; (5) a displaced family; (6) the remaining member of a tenant family; or (7) a single person who is not elderly, near-elderly, displaced, or a person with disabilities. Condition: During testing, it was noted that the Authority did not have adequate internal controls designed to ensure compliance with eligibility requirements. Questioned Costs: $7,936 Context: During our testing of a sample of 60 tenant files, it was noted that 20 files did not comply with compliance requirements.  1 instance where the income reported on the 50058 were not supported within the tenant file.  2 instances where the expenses reported on the 50058 were not supported within the tenant file.  3 instances where the housing authority failed to calculate the correct HAP/TAP  19 instances where the housing authority did not review the family income, assets and expenses on an annual basis. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Authority is not in compliance with federal regulations regarding eligibility, including the calculation of tenant rent, HAP and verification of the tenants income. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend that management review their controls over recertifications and ensure compliance standards for eligibility of tenants and HAP calculations are met. We also recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding. Following CLA’s recommendation, SVP of Housing Choice will audit a random sample of 10 files on a monthly basis. Agency working with Human Resources contractor to fill open staff positions.

Categories

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

Other Findings in this Audit

  • 401543 2023-003
    Significant Deficiency
  • 401544 2023-003
    Significant Deficiency
  • 401545 2023-004
    Significant Deficiency Repeat
  • 401546 2023-004
    Significant Deficiency Repeat
  • 401547 2023-005
    Material Weakness Repeat
  • 401549 2023-006
    Significant Deficiency Repeat
  • 401550 2023-006
    Significant Deficiency Repeat
  • 401551 2023-007
    Significant Deficiency Repeat
  • 401552 2023-008
    Significant Deficiency
  • 977985 2023-003
    Significant Deficiency
  • 977986 2023-003
    Significant Deficiency
  • 977987 2023-004
    Significant Deficiency Repeat
  • 977988 2023-004
    Significant Deficiency Repeat
  • 977989 2023-005
    Material Weakness Repeat
  • 977990 2023-005
    Material Weakness Repeat
  • 977991 2023-006
    Significant Deficiency Repeat
  • 977992 2023-006
    Significant Deficiency Repeat
  • 977993 2023-007
    Significant Deficiency Repeat
  • 977994 2023-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $38.10M
14.872 Public Housing Capital Fund $4.40M
14.850 Public and Indian Housing $3.32M
14.889 Choice Neighborhoods Implementation Grants $1.87M
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $108,020