Finding 45503 (2022-004)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2022
Accepted
2023-02-08
Audit: 45566
Organization: Detroit Housing Commission (MI)

AI Summary

  • Core Issue: Incomplete participant files led to incorrect benefit calculations, resulting in overpayments of $21.
  • Impacted Requirements: The Commission failed to meet federal criteria for verifying tenant income eligibility and conducting annual reexaminations.
  • Recommended Follow-Up: Implement stronger controls and training for staff on eligibility calculations, and conduct regular quality control reviews of tenant files.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name U.S. Department of Housing and Urban Development Direct programs Low income Public Housing and Development 14.850a Federal Award Identification Number and Year Not applicable Pass through Entity Not applicable Finding Type Significant deficiency Repeat Finding No Criteria Under 24 CFR 5.230, 5.601, 5.609, 960.206, 960.208, 960.253, 960.255, 960.257, and 960.259, the Commission must: a. As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Commission to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income, (2) the value of assets, (3) expenses related to deductions from annual income, and (4) other factors that affect the determination of adjusted income or income based rent. c. Determine income eligibility and calculate the tenant?s rent payment using documentation from third party verification. d. Select tenants from the public housing waiting list (see special tests and provisions public housing waiting list). e. Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification. Condition Participant files selected for testing did not include complete information to support the level of benefits provided. Questioned Costs $21 Identification of How Questioned Costs Were Computed Questioned costs were computed on the individuals below by identifying overpayments of subsidy charged compared to the appropriate amount. Context A total of 60 tenant files were tested, and the results are as follows: Of the files tested, one participant lacked income support and upon recalculation of income there was an increase in tenant rent. 2 participant files used the incorrect utility reimbursement amount, resulting in a miscalculation of tenant rent. Cause and Effect The Commission does not have the proper controls in place to ensure proper compliance with regard to tenant eligibility requirements. Due to the lack of adequate controls, questioned costs for overpayment of subsidy were identified above. Recommendation The Commission should establish procedures to ensure participant eligibility is accurately calculated and reviewed annually. Periodic internal review of tenant files would help identify errors in a timely manner. Views of Responsible Officials and Planned Corrective Actions While the Detroit Housing Commission works towards implementing Rent Cafe, an electronic platform to allow applicants, residents, and management the ability to streamline the continued occupancy and eligibility process, the Commission will continue to utilize the manual application process with the following controls in place: 1. There will be ongoing training to support staff in public housing rent calculation. Within the designated training, housing specialists, property managers, assistant property managers, and compliance specialists will focus on correctly calculating subsidy for applicants and residents. Trainings will include, but are not limited to, properly identifying and verifying income, expenses, allowances, adjusted income, total tenant payment (TTP), utility standards, PHA payment, and subsidy standards. 2. Regional managers will conduct the first line of quality control file reviews. Upon housing specialist, property manager, and assistant property manager completing initial eligibility, annual, and interim recertifications, regional managers will review the proposed certification against the certification?s checklist for approval. 3. The compliance department will conduct ongoing quality control file reviews on a 10 percent sample selection of households to ensure timely completion and accuracy of ongoing participant rent determination. a. When deficiencies are identified during a quality control review, site staff will have seven days to cure and upload the corrective file to SharePoint. b. The final quality control review will also include reconciliation for acceptance of the electronic file to PIC. 4. To address the incorrect utility allowance amounts being utilized to calculate tenant rent, the following will occur: a. The Commission?s REM department will work with the Commission?s IT department to update the utility allowance tables in the housing?s Yardi software. Current utility allowances will be entered in the software?s utility allowance table and will prepopulate based on the action type and effective date of the recertification. b. Site staff will include the printed utility allowance chart within the certification with the allowance amount provided clearly identified for review by the regional manager when conducting the first line of quality control file review.

Categories

Questioned Costs HUD Housing Programs Cash Management Eligibility Significant Deficiency Special Tests & Provisions Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 45502 2022-004
    Significant Deficiency
  • 45504 2022-001
    Material Weakness
  • 45505 2022-002
    Material Weakness
  • 45506 2022-003
    Material Weakness
  • 45507 2022-001
    Material Weakness
  • 45508 2022-002
    Material Weakness
  • 45509 2022-003
    Material Weakness
  • 45510 2022-001
    Material Weakness
  • 45511 2022-002
    Material Weakness
  • 45512 2022-003
    Material Weakness
  • 621944 2022-004
    Significant Deficiency
  • 621945 2022-004
    Significant Deficiency
  • 621946 2022-001
    Material Weakness
  • 621947 2022-002
    Material Weakness
  • 621948 2022-003
    Material Weakness
  • 621949 2022-001
    Material Weakness
  • 621950 2022-002
    Material Weakness
  • 621951 2022-003
    Material Weakness
  • 621952 2022-001
    Material Weakness
  • 621953 2022-002
    Material Weakness
  • 621954 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $39.94M
14.850 Public and Indian Housing $17.60M
14.872 Public Housing Capital Fund $10.09M
14.871 Covid-19 Housing Choice Vouchers $612,989
14.879 Mainstream Vouchers $383,880
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $378,630
14.850 Covid-19 Public and Indian Housing $349,028
14.870 Resident Opportunity and Supportive Services - Service Coordinators $187,423
14.896 Family Self-Sufficiency Program $130,377
14.895 Jobs-Plus Pilot Initiative $70,120