Finding 44896 (2022-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2022-10-17

AI Summary

  • Core Issue: 27 out of 120 tenant files were recertified late, violating federal regulations.
  • Impacted Requirements: Annual income and composition reexaminations must be completed on time to avoid funding loss.
  • Recommended Follow-up: Identify non-compliant vouchers and enforce adherence to the Administrative Plan and regulations consistently.

Finding Text

Finding 2022-001 ? Housing Choice Voucher Program Tenant Files ? Eligibility ? Internal Control over Tenant Files ? Noncompliance and Significant Deficiency ? Housing Choice Voucher Program ? Subsidy CFDA #14.871 Criteria: The Code of Federal Regulations, the Housing Authority?s Admin Plan, and specific HUD guidelines in documenting and maintaining the Housing Choice Voucher tenant files. Condition & Cause: Our review of one hundred and twenty (120) Housing Choice Voucher tenant files revealed that there was a total of twenty-seven (27) annual recertifications completed past due, which represent 22.5% of the total files examined. Per 24 CFR 982.516(a)(1), ?the PHA must conduct a reexamination of family income and composition at least annually.? Per PIH Notice 2021-14, ?All annual reexaminations due in CY 2021 must be completed by December 31, 2021. All annual reexaminations that were due in Calendar Year 2020 (CY20) must have been completed by December 31, 2020.? There has been significant employee turnover and delays due to the Coronavirus pandemic. The Housing Authority experienced extreme difficulty in obtaining all the information necessary for the annual recertification. Also, the remedy for failure to obtain all the information is to begin the eviction procedures of the residence. This was not practically possible due to the pandemic. Effect: Failure to maintain compliance can result in loss of funding for grants and other programs which require operations to have no audit findings and noncompliance. Noncompliance can also lead to a misstatement of HAP expense, HAP equity, and the corresponding appropriation needs of the Agency. Recommendation: We recommend that the Agency determine which vouchers are not in compliance and begin enforcing both the Administrative Plan and the Code of Federal Regulations on a consistent basis.

Corrective Action Plan

Fiscal Year Ending (?FYE?) 2022 Audit Response Corrective Action Plan Finding 2022-001 ?Housing Choice Voucher Program Tenant Files ?Eligibility-Internal Control over Tenant Files-Noncompliance and Significant Deficiency? RHA Response The Raleigh Housing Authority and Leased Housing Department acknowledge and accept that there were a significant number (27 files of 120 reviewed) of past due annual recertifications during the FYE 2022 review period. The abundance of outstanding annual re-exams started mid-2020. During the height of the Coronavirus pandemic, we changed our process for in-person appointments for completing the Annual Re-exam paperwork to mailing the packets to the families. This caused us problems with obtaining the necessary documentation for processing the recertifications. Also, other agencies that provided the required income/household verifications were closed and families were unable to obtain the required information. The Leased Housing Department modified its procedures and accepted what was minimally allowable based on HUD?s guidance. The staff worked diligently with the families that had outstanding documents to avoid terminating the families which would have likely resulted in homelessness during a national pandemic. There was a moratorium in place that prevented evictions of tenants during that time also. The Leased Housing Department also had a number of vacant positions during this review period. The Client Manager worked a large portion of the previous review period FYE 2021 with two full-time staff person and 2 temporary employees during part of that time. In a department that normally worked with 4 full-time trained employees, this staff reduction and having to train temporary employees slowed the process down. The Leased Housing staff has put the following plan in place to catch up on our annual recertifications and to complete timely moving forward: ? Additional Staffing positions to hire and train o one (1) client specialist ? this team gathers all the required documents and confirms completed properly o two (2) account specialist ? this team calculates the annual recertification income and generates the 50058s transmitted to HUD ? Current staffing positions reassigned to assist including: o 2 Temporary employees o Compliance Officer o Contract Specialist o 2 File Review Specialist ? from Finance Compliance team o Client Manager ? Contract with an outside service provider to help with the volume - We have received quotes from both Nan McKay and Quadel and will look to procure within the next few weeks to help us move through the volume of past due files ? A new tracking system for Annual recertification has been implemented to ensure the number of Annual Re-exams that need to be processed weekly are meet to meet our monthly goals. ? The Client Manager and the Assistant Director of Leased Housing will meet weekly to discuss the progress and work together to meet the monthly lease-up goal. ? Voucher families will be scheduled to come-into the office to pick-up the annual recertification packet and speak to their assigned specialist if needed. ? Voucher families are notified 90-days prior to their annual recertification date and given a time and date to submit the requested documents. If requested documents are not received, the voucher family will receive a pre-term letter with a scheduled appointment to come into the office and meet with the assigned Client Specialist. They will only be given 7-business days to return requested documents after this meeting. If not received the family will be issued a letter of termination. Anticipated Completion: 12/31/22 Person Responsible: Liz Edgerton Respectfully, Liz Edgerton Interim Director

Categories

HUD Housing Programs Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 621338 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $35.02M
14.850 Public and Indian Housing $4.85M
14.872 Public Housing Capital Fund $2.28M
14.871 Covid-19 - Section 8 Housing Choice Vouchers $589,168
14.871 Ehv - Section 8 Housing Choice Vouchers $549,850
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $362,186
14.850 Covid-19 - Public and Indian Housing $27,435