Finding 47050 (2022-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-08-02

AI Summary

  • Core Issue: The Authority is not maintaining consistent contact with Family Self Sufficiency (FSS) participants, violating both federal regulations and internal policies.
  • Impacted Requirements: Noncompliance with 24 CFR 984.303 regarding monthly check-ins and documentation of participants' goals and progress.
  • Recommended Follow-Up: Ensure regular communication with all participants and maintain accurate records to support program integrity and proper fund disbursement.

Finding Text

Finding 2022-002 ? Family Self Sufficiency Program ? Special Provisions ? Noncompliance & Significant Deficiency Family Self Sufficiency Program ? ALN#14.896 Condition: We reviewed a total of twenty (20) FSS participant files, ten (10) under the Public Housing program and ten (10) under the HCV program. Per the FSS Action Plan, the Authority should maintain contact with each participant on a monthly basis, as well as maintaining records of each participant?s goals. We found that nine (9) of the participants had not been in consistent contact with their assigned specialist, some of these as far back as 2020. We found three (3) files in which the applicable Individual Training and Service Plans (ITSP?s) were not signed by the participant. We also noted that there was a lack of documentation that participants graduating from the program had met their goals. The Authority is not in compliance with CFR 984.303 Contract of Participation. They are also not following the internal policies governing FSS administration regarding monthly check-ins with the participants. Criteria: Regulations at 24 CFR 984.303 outline the requirements of the FSS program. Each participating FSS family must enter into a Contract of Participation with the PHA, which stipulates interim and final goals. This should include the ITSP for the head of household. The Authority?s internal policy also dictates that the Authority should maintain contact with the participants on a monthly basis. Cause: Controls over the administration of the FSS program do not appear to be in place or operating effectively. Effect: When the program is not maintained in compliance with 24 CFR 984.303 this can result in a possible error in retaining a client on the program. Consequently, when it is not clear whether a client should remain on the program there might be an error from rent and HAP payment amounts. Additionally, as a result of noncompliance the expenditures in a program may be disallowed and the grant income recovered. Recommendation: We recommend that the Authority maintain proper records relating to the participant?s goals under the program. We also recommend that the Authority maintain consistent contact with all program participants. Consistent contact ensures participants are meeting program and personal goals, as well as providing participants with effective support when needed, while proper documentation is pertinent to valid and accurate disbursement of escrow funds upon completion of the program. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

FINDING 2022-002 ?Family Self-Sufficiency Program ? Special Provisions ? Non-Compliance and Significant Deficiency? SHA RESPONSE The Springfield Housing Authority acknowledges that the Family Self-Sufficiency program files did not adequately document client engagement activities provided by FSS staff. The SHA attributes two factors to this deficiency: the inability to meet in-person with program participants during the COVID-19 pandemic negatively impacted the staff-client relationship and SHA FSS staff did not properly document contacts with participants in participant files. Further, through internal quality control reviews, the Springfield Housing Authority recognized program leadership was prohibiting successful implementation of the FSS program, identified program deficiencies and implemented changes necessary to correct identified deficiencies. The SHA will take the following corrective actions to correct the errors and/or prevent the errors moving forward: ? The Director of Self-Sufficiency Programs will conduct reviews of 100% of FSS participant files on a weekly basis to ensure monthly meetings are scheduled with FSS participants and the outcome of said meetings, to ensure all contractual and programmatic forms are executed properly and file documentation systems are maintained, etc. ? The Director of Self-Sufficiency Programs and Family Self-Sufficiency Specialists will be provided with additional internal and external training opportunities relative to FSS Program Best Practices and Case Management by December 31, 2023. ? 100% of SHA FSS Staff will be provided with and certified in HUD Family Self-Sufficiency Program training. ? The Director of Self-Sufficiency Programs will re-review the files identified with errors during the independent audit and resolve the errors in accordance with the SHA HUD Approved FSS Action Plan and HUD rules and regulations by September 30, 2023. PERSON RESPONSIBLE Melissa Huffstedtler ANTICIPATED COMPLETION DATE December 31, 2023

Categories

HUD Housing Programs Allowable Costs / Cost Principles Significant Deficiency Special Tests & Provisions

Other Findings in this Audit

  • 47049 2022-001
    Significant Deficiency Repeat
  • 623491 2022-001
    Significant Deficiency Repeat
  • 623492 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $14.13M
14.850 Public and Indian Housing $3.58M
14.872 Public Housing Capital Fund $1.95M
14.879 Mainstream Vouchers $957,732
14.896 Family Self-Sufficiency Program $224,018
14.871 Ehv - Section 8 Housing Choice Vouchers $122,796
14.870 Resident Opportunity and Supportive Services - Service Coordinators $62,387