Finding 429 (2020-002)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2020
Accepted
2023-10-20

AI Summary

  • Core Issue: The Authority failed to perform annual recertifications for 19 out of 44 tenant files tested, indicating a material weakness in internal controls.
  • Impacted Requirements: Compliance with HUD regulations and the Authority’s Administrative Plan regarding timely and accurate tenant file management is not being met.
  • Recommended Follow-Up: The Authority should review and improve procedures to ensure compliance, address deficiencies in the tested files, and assess the impact on the entire tenant population.

Finding Text

2020-002 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 17,476 tenants, 44 tenant files were tested and the following deficiencies were noted: • Nineteen files did not have annual recertifications performed during the year. Criteria: The Authority’s 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 randomly selected 44 tenant files out of the population, 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 during the onset of COVID and did not have the available staff to follow the established internal controls to ensure proper compliance with regards to timely 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: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. 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

2020-002 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 17,476 tenants, 44 tenant files were tested and the following deficiencies were noted: • Nineteen files did not have annual recertifications performed during the year, • Seven files did not have correct utility allowance or documentation required to determine correct utility allowance, • Six files did not have 9886 release of information forms with 15 months of annual recertification, • Five files had HAP payments that did not agree to the HAP register, • Two files did not have rent reasonableness performed under a circumstance were it would be required to, • Two tenants did not have inspections performed during the year, • One file had an incorrect HAP calculation, and • One file did have the required forms of identification documented. Auditor’s Recommendations: The Authority should consider reevaluating their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. 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. Action Taken: Leadership of the Houston Housing Authority acknowledges this issue and agrees with the finding. To eliminate the number of delinquent recertifications management of the HHA program has undertaken a project to eliminate all of the delinquencies and maintain the current status of those HCVP files where the recertification is not delinquent. An incentive plan has been created where certain HCVP staff will be granted overtime in the case of hourly employees and paid an incentive in the case of salaried employees to eliminate the existing backlog of delinquent recertifications. Each employee who works on this program is to be verified that they have the training necessary to work on the recertifications. In addition if recertifications are part of their normal work load they will have to maintain the pace that is necessary to not create additional delinquencies in order to participate in the incentive program. Hourly employees who are not successfully contributing to the project will be either be offered additional training or removed for eligibility to participate. Salaried employees will be compensated on a completed file basis with the HUD PIC acceptance of the data as the benchmark for completion and receipt of the incentive pay for the completed recertification. The HCVP management staff is confident that they can eliminate the backlog prior to the end of the 2023 calendar year.

Categories

HUD Housing Programs Eligibility Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 430 2020-002
    Material Weakness
  • 431 2020-002
    Material Weakness
  • 576871 2020-002
    Material Weakness
  • 576872 2020-002
    Material Weakness
  • 576873 2020-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.269 Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (cdbg-Dr) $19.26M
14.850 Public and Indian Housing $15.26M
14.871 Section 8 Housing Choice Vouchers $12.85M
14.872 Public Housing Capital Fund $5.45M
14.239 Home Investment Partnerships Program $2.81M
14.267 Continuum of Care Program $2.75M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $2.40M
14.879 Mainstream Vouchers $1.64M
14.182 Section 8 New Construction and Substantial Rehabilitation $1.63M
14.218 Community Development Block Grants/entitlement Grants $479,366
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $329,662
14.895 Jobs-Plus Pilot Initiative $162,340
14.191 Multifamily Housing Service Coordinators $51,621