Finding 402814 (2023-002)

Finding 2023-002 – Continuum of Care Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness Continuum of Care Program - subsidy ALN 14.267 Condition & Cause: We selected a sample of five (5) files for review. We noted the following errors of noncompliance: • Two (2) files which disagreed with the applicable HAP register due to delays in annual or interim updates; • Two (2) files which contained no paperwork pertaining to the period examined; and • One (1) file which contained a miscalculation of annual income and no signed authorization for the release of information. We noted that subsequent to year end new staff was placed in charge of the program. Per discussion, the focus has been bringing current participants into compliance. We elected to randomly sample an additional five (5) files from a list of current participants subsequent to year end. We reviewed these files for existence, presence of the action in agreement with the March 2024 HAP register, and timeliness of completion of annual reexaminations. This subsequent review revealed: • Two (2) files for which the recertification was completed more than three months past the due date; • One (1) file in which there was no documentation of the annual update; and • One (1) file which staff was unable to locate. Criteria: The Code of Federal Regulations 24 part 578, the Housing Authority’s Admin Plan, and specific HUD guidelines in documenting and maintaining the Continuum of Care tenant files. Effect: Failure to conduct timely recertifications and to properly calculate HAP can result in a misstatement of HAP expense leading to improper funding for the CoC program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding. Recommendation: We recommend that the Agency conduct a thorough tenant file audit of existing tenants in the Continuum of Care program. We also recommend that the Agency increase their monitoring and review of the Continuum of Care program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Questioned Costs: None Repeat Finding: Yes Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.