Finding
No.
2023-002 Tenant Files: Eligibility
Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871)
Type of Finding: Material non-compliance and Material Weakness in Internal Control over Compliance
This is a repeat finding of 2022-002 from September 30, 2022 (Originally reported as finding 2019-001 from September 30, 2019)
Statement of Condition: Out of a total tenant population of approximately 1,142 vouchers, 25 files were selected for testing, and the following errors were discovered.
• 1 tenant file had the following error:
o The utility allowance was miscalculated by $32 (overstatement). The two-bedroom column utility rates were used when the 1-bedroom column utility rates should have been used. Correcting this error would cause which the HAP rent to decrease from $762 to $731.
• 1 tenant file had the following error:
o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period.
• 1 tenant file had the following error:
o The utility allowance was miscalculated by $23 (understatement). The 2022 utility allowance schedule was used when the 2023 utility allowance schedule should have been used. Correcting this error would cause the HAP rent to increase from $494 to $517.
• 1 tenant file had the following error:
o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen.
• 1 tenant file had the following error:
o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period.
• 1 tenant file had the following error:
o The tenant’s asset income was miscalculated. Correcting this error would increase the HAP rent by $4.
• 1 tenant file had the following error:
o The 50058-form reported childcare income support of $6,000, however, the support for the childcare income showed $5,800. Correcting this error had no effect on the HAP rent.
• 1 tenant file had the following error:
o No support for the tenant’s wage income of $23,296 on the 50058 form. Appears to be reported correctly, since the EIV shows an amount that approximates the tenant’s wage income of $23,296. Nonetheless, there needs to be support in the tenant file for the wage income.
o Missing HAP contract.
• 1 tenant file had the following error:
o The utility allowance was miscalculated by $19 (understatement). Correcting this error would cause the HAP rent to increase from $924 to $943.
In addition to the above, we noted the following during our new admissions testing (out of a total of 161 new admissions, 17 files were selected for testing.):
• 1 tenant file had the following error:
o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen.
• 1 tenant file had the following error:
o HAP contract was not executed timely (within 60 days).
• 1 tenant file had the following error:
o The voucher extension date was not documented on the voucher.
• 1 tenant file had the following error:
o The request for tenancy addendum was executed (dated) two days after the voucher extended due date.
o The unit size on the voucher did not agree to the family voucher size on the 50058 and the wrong payment standard was applied to the tenant.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants.
The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being to the Housing Programs Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the new Intake Counselor, have attended Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam.
Effective Date: June 21, 2024
Contact Information
Gwendolyn B. Dawson, CEO
Ocala Housing Authority
1629 NW 4th Street
Ocala, Florida 34475
(352) 369-2636