Finding 404439 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-06-28

AI Summary

  • Core Issue: The Authority failed to conduct timely Housing Quality Standards (HQS) inspections, leading to noncompliance with federal requirements.
  • Impacted Requirements: Inspections were overdue for 15 tenants, and inspection reports for 7 tenants were missing, violating 24 CFR 982.158 and 982.405.
  • Recommended Follow-Up: The Authority should improve its internal controls, ensure timely inspections, and enhance record-keeping practices to prevent future issues.

Finding Text

Finding Reference: 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Criteria Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority was required to resume biennial inspections by December 31, 2021. The Authority was required to conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and was required to conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022. Condition From a total population of about 15,410 tenants for the fiscal year ended September 30, 2023, we selected a statistically valid sample of one monthly subsidy payment for each of 60 selected tenants, and identified fifteen tenants whose HQS inspections were completed past the due dates and seven tenants whose HQS inspection reports were not provided for review. Cause of Condition The Authority’s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed. Effect The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality. Questioned Costs Known questioned costs of $179,377 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 60 participants that totaled $1,550,585 in HAPs to the total HAPs of $385,748,113 for the year, results in likely questioned costs of $44,624,677. Identification of Repeat Finding This is a repeat of finding 2022-003 reported for the year ended September 30, 2022. Recommendation The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems. View of Responsible Officials and Planned Corrective Action See separately prepared Corrective Action Plan.

Corrective Action Plan

Reference Number: 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance The Authority has made considerable progress in addressing the backlog of annual inspections that resulted from the implementation of HUD waivers during the national pandemic. The Authority acknowledges that more progress in this area is required and continues to work diligently with its third-party HCV contractors to ensure completion of this ongoing work. The Authority understands the importance of and is committed to ensuring all units under contract are beyond safe, sanitary, and decent in accordance with HQS requirements and the Authority's Administrative Plan. The Authority uses the Emphasys Elite software to check against HUD's PIH Information Center (PIC) system to identify units with outstanding Housing Quality Standards (HQS) Inspections. The Authority has scheduled HQS Inspections for the units identified to be out of compliance. Some key strategies and controls in place are as follows: Review the report of outstanding HQS Inspections on a weekly basis. Schedule outstanding HQS Inspections in order of aging date. Conduct HQS Inspections prior to anniversary date of previously completed inspection. Run a monthly report of failed inspections and compare them with future scheduled inspections to ensure that a second inspection has been scheduled. Run a monthly report to identify units with two failed inspections to ensure all have been abated correctly. Implement weekly monitoring to ensure all units are properly abated and lifted timely when units pass inspections and contracts are properly terminated after being in abatement for 180 days without a cure. During the pandemic, units were not inspected and legally permitted based upon available HUD regulations. As a result, the Authority has implemented a 100% Annual Inspection requirement for all contracted project-based vouchers (PBVs) and tenant-based vouchers (TBVs) units starting with the 10/1/2023 HUD Section Eight Management Assessment Program (SEMAP) Year. To that end, the HCV contractors have implemented a daily review process for all failed inspections to ensure timely rescheduling and will accurately note inspection extension requests exceeding the 30-day HQS enforcement requirement to bring a unit up to standard. Anticipated Implementation Date September 30, 2024 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

Categories

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

Other Findings in this Audit

  • 404440 2023-002
    Material Weakness Repeat
  • 404441 2023-002
    Material Weakness Repeat
  • 404442 2023-003
    Significant Deficiency
  • 404443 2023-003
    Significant Deficiency
  • 980881 2023-002
    Material Weakness Repeat
  • 980882 2023-002
    Material Weakness Repeat
  • 980883 2023-002
    Material Weakness Repeat
  • 980884 2023-003
    Significant Deficiency
  • 980885 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $14.98M
14.879 Mainstream Vouchers $6.04M
14.850 Public and Indian Housing $5.46M
14.872 Public Housing Capital Fund $1.82M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $1.02M