Finding Text
Finding 2023-001 – U.S Department of Housing and Urban Development – Housing Voucher Cluster – Program Documentation (Significant Deficiency)
Criteria: The Uniform Guidance requires that HALC maintain proper documentation to demonstrate compliance with the requirements of the program.
Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements:
•Special Tests:
o Reasonable rent
o Utility allowance schedule
o Waiting list
During our testing over reasonable rent, auditor noted 1 of the 60 selections tested had no documentation that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required.
During our testing over the utility allowance schedule, auditor noted that the updated utility allowance rates were received on July 20, 2023. However during our file review, the updated rates were not used in re-certifications until December 2023.
During our testing over the waiting list, HALC was unable to provide support the waiting list was pulled or examined by the Housing Program Manager ensuring accuracy of the list order and mailing of the top of the list letters for 8 of the 25 selections. Seven of the deficient samples were in the first 6 months of the year, prior to the FY22 audit findings. The control over the waiting list appears to have been implemented more effectively in the second half of the year. Additionally, auditor noted 2 of the 25 selections were admitted into the program but no support was provided indicating the participants top of list letter agreed to the monthly waiting list report and in proper order with other applicants on the monthly waiting list report.
Cause: The Authority experienced a high degree of personnel turnover from 2020 through 2022. HALC’s Executive Director who had many years of HUD experience retired in December 2022 and personally performed several duties related to the Housing Choice Voucher program, as well as the Authority experiencing several housing assistant staff turnovers annually. Along with experiencing a high degree of personnel turnover, the Authority also experienced insufficient staffing levels overall.
Effect: Lack of reasonable rent comparisons, utility allowance updates, and waiting list compliance could result in improper rental payments, housing that does not meet quality standards, insufficient utility payments, or applicants admitted into the program out of order.
Identification of Repeat Finding: This is a repeat finding from prior year (See 2022-002), although this year they have been downgraded from material weaknesses to significant deficiencies because the number of deficiencies decreased and the proper utility rates were used in December.
Recommendation: The Authority should:
• Strengthen the training available to staff that are responsible for determining and documenting compliance with each of the compliance requirements.
• Strengthen the review process of tenant files by management so that errors will be identified prior to payments being made to landlords on the tenant’s behalf.
• Train additional members of management and staff to perform and back-up the compliance duties related to the Section 8 program.
Views of Responsible Officials and Planned Corrective Action Plan: There is no disagreement with these findings. Management has taken steps to remedy the errors, such as hiring a third-party vendor to assist in the calculation and determination of utility allowances, cross-train current staff to perform other duties related to the Housing Choice Voucher program and attend additional Housing Choice Voucher trainings.