FAC Explorer

Finding 404748 (2023-002)

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Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-06-29
Audit: 311131
Organization: Homes for Good Housing Agency (OR)
Auditor: Berman Hopkins Wright & Laham CPAS and Associates

AI Summary

  • Core Issue: There are multiple deficiencies in tenant files, including incorrect income calculations and missing documentation.
  • Impacted Requirements: Compliance with HUD requirements and the Authority’s internal controls is lacking, affecting eligibility determinations.
  • Recommended Follow-Up: The Authority should review and improve procedures to correct identified deficiencies and ensure compliance across all tenant files.

Finding Text

Condition: Out of an approximate population of approximately 3,900 tenants, 86 tenant files were tested and the following deficiencies were noted: • One file did not complete the income calculation correctly, • One file did not have a 214 declaration form for all members of the household, • One file did not have the required form of identification documented, • Two files did not have the unit inspection for the prior 3 years, • Two files did not have the required support to prove dependency. Criteria: The Authority’s Moving to Work (“MTW”) Annual Plan, Administrative Plan and 24 CFR 982.516 requires internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor haphazardly selected 86 tenants which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges, which is impacting the housing industry as a whole and did not have the available staff to follow the established internal controls to ensure proper compliance with regards to recertifications and collection of required HUD documentation to verify eligibility and calculate accurate housing assistance payments. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: Unknown. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: See Corrective Action Plan.

Corrective Action Plan

PLAN OF ACTION RESPONSE TO FY23 FINDINGS & QUESTIONED COSTS SIGNIFICANT DEFICIENCY Action Timeframe Responsible Person Training will be provided to staff on a quality control protocol, specifically, the importance of proper calculations; obtaining necessary documentation; and the importance and process for following up on inspections July 31, 2024 Beth Ochs Rent Assistance Director Quality control by manager will be performed on all files assigned to probationary employees July 31, 2024 Beth Ochs Rent Assistance Director Establish an updated checklist for staff to follow to ensure proper documentation is obtained on each file September 30, 2024 Beth Ochs Rent Assistance Director Pull reports out of the EIV/PIC system, on a monthly basis, such as the Identity Verification Report, SSA Screening Deficiencies Report and place them in a centrally located OneNote for staff follow up. Note: This has been on pause due to the conversion to new software July 31, 2024 Beth Ochs Rent Assistance Director Establish a plan to schedule overdue inspections and complete inspections December 31, 2024 Beth Ochs Rent Assistance Director Assigned caseworker staff will correct the tenant files that were cited in the “other matter” finding in the FY 23 Audit August 30, 2024 Beth Ochs Rent Assistance Director Randomly select tenant files on a monthly basis for review. Note: This has been on pause due to the conversion to new software and will resume in July 2024 July 31, 2024 Beth Ochs Rent Assistance Director Randomly select an additional 50 HCV tenant files beyond the FY 23 audit sample of 86 and review them for the following compliance finding, to test: 1. Income calculations 2. 214 declarations for all members 3. ID documentation for all members 4. Unit inspections 5. Proof of dependents in Household August 30, 2024 Beth Ochs Rent Assistance Director

Categories

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $31.89M
14.871 Emergency Housing Voucher $2.60M
10.415 Rural Rental Housing Loans $1.99M
14.871 Section 8 Housing Choice Vouchers $1.97M
14.879 Mainstream Vouchers $1.45M
81.042 Weatherization Assistance for Low-Income Persons $1.31M
14.238 Shelter Plus Care $856,345
21.023 Emergency Rental Assistance Program $605,671
93.468 American Rescue Plan Act $588,285
93.568 Low-Income Home Energy Assistance $543,984
14.267 Continuum of Care Program $363,279
14.103 Interest Reduction Payments_rental and Cooperative Housing for Lower Income Families $318,772
14.182 Section 8 New Construction and Substantial Rehabilitation $263,417
10.427 Rural Rental Assistance Payments $260,821
14.896 Family Self-Sufficiency Program $228,731
64.024 Va Homeless Providers Grant and Per Diem Program $102,166
14.870 Resident Opportunity and Supportive Services - Service Coordinators $83,547