Finding 496766 (2023-001)

Material Weakness Repeat Finding
Requirement
Eligibility
Questioned Costs
$1
Year
2023
Accepted
2024-09-13

AI Summary

  • Core Issue: The Housing Authority of the City of Pittsburgh has repeated issues with internal controls, leading to incomplete tenant recertifications and missing documentation.
  • Impacted Requirements: The Authority must submit accurate HUD-50058 forms for tenant eligibility and maintain supporting documents to ensure proper rent calculations and compliance.
  • Recommended Follow-Up: Implement stronger procedures for timely recertifications, ensure all documentation is collected, and provide training to mitigate future turnover impacts.

Finding Text

Finding 2023-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021 (2021-001) and 2022 (2022-001) Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted 4 instances where a tenant recertification using the HUD-50058, Family Report (OMB No. 2577-0083) form (which provides eligibility and reporting information) was either not completed, or not completely on a timely basis. We also noted multiple instances where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 that we were able to review was not provided. This includes items such as rent reasonableness forms, support for income calculation, signed and approved HAP contracts and lease agreements, and signed HUD Form 9886. Criteria: The Authority is required to prepare and submit HUD-50058 form each time the Authority completes an admission, annual reexamination, portability move-in, or other change of unit for a family. The form provides HUD and the Authority with vital eligibility data for each program participant such as family composition, family income, the assets and liabilities of program participants, and ultimately provides for the calculation of tenant rent and rental/housing assistance payments for each program participant. In relation to the missing documents noted above, these documents are to be maintained to support the eligibility of the tenant, and are also required to be maintained to provide support for the tenant income and eligibility determinations completed on the HUD-50058 form. The signed lease and HAP contracts are also required to ensure appropriate amounts are used in calculation subsidy payments, and appropriate payments are made to landlords for the housing provided. Cause: There was a lack of functioning internal control over the recertification process that were exacerbated by turnover and logistical staffing challenges. Effect: HUD-50058 forms provide essential information to HUD as well as being used by the Authority to determine program eligibility. In addition, the HUD-50058 form is used for the calculation of tenant rent and rental/housing assistance payments. Without this required documentation, this could lead to ineligible tenants being housed through the Authority program, and/or overpayments or underpayments of rental assistance, and incorrect information being reported to HUD. Questioned Costs: Unknown Recommendation: We recommend that the Authority implement additional procedures to ensure biennial recertification and the related HUD-50058 forms are prepared timely and accurately and that all supporting documentation is obtained and retained. In addition, appropriate training and planning should be performed to ensure that future turnover in the organization does not lead to a lapse in internal controls over compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.

Corrective Action Plan

Maher Duessel Finding Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted 4 instances where a tenant recertification using the HUD-50058, Family Report (OMB No. 2577-0083) form (which provides eligibility and reporting information) was either not completed, or not completely on a timely basis. We also noted multiple instances where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 that we were able to review and was not provided. This includes items such as rent reasonableness forms, support for income calculation, signed and approved HAP contracts and lease agreements, and signed HUD Form 9886. HACP Management Response/Action Taken: Action Taken: The HACP will continue to monitor and train staff regarding processes and procedures, to include and not limited to the HUD's hierarchy of income verification. In fiscal year (FY) 2023 the HCV Department had a significant turnover in line and managerial staff. The HACP promoted an aggressive hiring plan to attract new talent to fill vacant positions due to the great resignation that the HACP along with other national Agencies continue to experience. In addition, the HACP retained the services of CVR and Associates to train newly hired staff on all aspects of the HCV Program, to include and not limited to recertifications, contracts, interims, and rent increases. The HACP will continue managerial and internal audits by the HACP Internal Compliance Department to reduce the necessity of corrections after the initial submission. The HACP continues to: • Send notices regarding re-certifications 120 days in advance of the due date, • Require Managers to review reports to assure timely submission of re-certifications, • Utilize the Internal Compliance (IC) Department to review and sample files from the Occupancy and the HCV portfolio, • Make corrections when discovered, • Make payment adjustments to participant accounts when errors are discovered and corrected, • The HACP will offer periodic staff training on re-certification, • The HACP offers participants the use of technology to complete paperwork. In 2024, the HCV Department successfully tested the implementation of pre-populated recertification forms. The pre-populated forms allow the participant to confirm or quickly modify family composition and income information. In addition to the time and cost saving factor of the pre-populated forms, the forms are less daunting to complete. The HACP contends It will receive more cooperation from participants in completing the forms because of the ease of use. During FY 2022, the HACP was closed to the public. In July of 2023, the HACP opened a "One Stop Shop" that is open to the public from 8 a.m. to - 4:30 p.m. daily. The One Stop Shop is staffed with three (3) full-time staff members to receive information from participants and landlords to provide timely customer service. In July of 2024 the OSS was equipped with computers for the public to access HACP staff virtually as well as in person. The use of the computers allows staff to interact with participants regarding minor issues without having the staff physically come to the OSS, thus saving time and money for both the external customer and the Agency. The opening of the One Stop Shop has been successful in receiving the public and responding to concerns.

Categories

Questioned Costs Eligibility HUD Housing Programs Reporting

Other Findings in this Audit

  • 1073208 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $137.70M
14.871 Section 8 Housing Choice Vouchers $1.05M
14.871 Section 8 Housing Choice Vouchers - Ehv $944,533
14.870 Resident Opportunity and Supportive Services - Service Coordinators $377,268
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $224,399
14.879 Mainstream Vouchers $156,380
14.896 Family Self-Sufficiency Program $121,217