Finding 404703 (2023-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-06-28

AI Summary

  • Core Issue: The Authority failed to obtain and document required tenant income verification.
  • Impacted Requirements: Compliance with eligibility criteria under 2 CFR for verifying family annual income.
  • Recommended Follow-up: Enhance policies and controls to ensure accurate income reporting and proper documentation retention.

Finding Text

Finding 2023-001: Missing Tenant Income Information Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Public and Indian Housing Federal Assistance Listing Number: 14.850 Compliance Requirement: Eligibility Criteria: Per 2 CFR, PHAs are required to obtain and document third party verification of reported family annual income. Condition: The Authority was unable to locate income verification documentation as well as reported the incorrect income amount on the Family Report. Context: Out of the 60 tenant files reviewed for income verification, 2 files did not have the documentation verifying income and 3 files did not have the correct income amount on the Family Report. Effect: The Authority did not verify income properly. Cause: The Authority did not have the proper controls in place to ensure tenant income was verified correctly. Repeat Finding: This is not a repeat finding. Recommendation: The Authority should review and enhance its policies, procedures, and internal controls to ensure the recertifications include the correct income amount and is adequately retained in the Authority’s files. Views of Responsible Officials: The Authority agrees with the finding.

Corrective Action Plan

CORRECTIVE ACTION PLAN (CAP) Since the end of audit period 9/30/2023 the Richmond Redevelopment and Housing Authority (RRHA) has accomplished a series of activities to improve the quality and accuracy of tenant file information and has created Corrective Action Plans (CAP) for continuous improvement, as outlined below: FY 2023 Activity to date: RRHA requested a review of RRHA policies and procedures regarding rent collection and tenant file management from Nan McKay Consultants. Nan McKay issued a memorandum certifying compliance of the agency’s policies and procedures with all related HUD requirements. CAP: RRHA will update its Standard Operating Procedures regarding tenant file management to comply with Admission and Continued Occupancy and Administrative Plan revisions that were part of the agency’s Annual Plans. FY 2023 Activity to date: Staff attended a Nan McKay Consultants rent calculation training September 26-28, 2023. In addition, RRHA staff attended a six-week training course that included a two-week skills development. In addition, a Corporate Trainer position has been budgeted and will be filled early in the first quarter of FY2025. CAP: RRHA will ensure quarterly refresher training for current staff and comprehensive training for new staff. FY 2023 Activity to date: The RRHA created a Chief Compliance Officer Position that coordinates and reports on all RRHA compliance activities. CAP: The RRHA will develop a Standard Operating Procedure for that Compliance Office that will include more extensive quality control reviews and statistically significant Internal Audit reviews of tenant files. NAME OF RESPONSIBLE PERSON: Tonise Webb, Associate Lead Counsel and Chief Compliance Officer EXPECTED COMPLETION DATE FOR CORRECTIVE ACTION PLANS: September 30, 2024

Categories

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 981145 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $34.87M
14.850 Public and Indian Housing $24.39M
14.872 Public Housing Capital Fund $12.01M
14.879 Mainstream Vouchers $1.30M
14.892 Choice Neighborhoods Planning Grants $314,499
14.870 Resident Opportunity and Supportive Services - Service Coordinators $212,684
14.896 Family Self-Sufficiency Program $83,573