Finding 499187 (2023-002)

- Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-09-27
Audit: 321980
Organization: New York City Housing Authority (NY)

AI Summary

  • Core Issue: Eight required eligibility forms were missing from case files, preventing verification of participant eligibility for the Public and Indian Housing Program.
  • Impacted Requirements: Compliance with HUD eligibility documentation standards is at risk, which may lead to non-compliance findings.
  • Recommended Follow-Up: Strengthen controls to ensure all eligibility forms are collected, reviewed, and maintained in case files to support eligibility determinations.

Finding Text

FINDING # 2023-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE PUBLIC AND INDIAN HOUSING (ALN # 14.850) CONTRACT #: NOT AVAILABLE FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 1. CRITERIA Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). 2. CONDITION/PERSPECTIVE The Authority received funding from the HUD. The Public and Indian Housing Program is to provide and operate cost effective, decent, safe, and affordable dwellings for lower income families through an authorized local PHA. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: • Eight eligibility forms were not provided (five missing application forms, one missing certifications information provided to the PHA forms and two missing Release form). These forms are required documentation to be maintained in the case files to support eligibility for Public and Indian Housing Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. 3. CAUSE The Authority did not ensure that all required eligibility forms were obtained from the tenants and included in the case files timely. 4. EFFECT The U.S. Department of Housing and Urban Development may consider the Authority non-compliant with the eligibility requirements. 5. REPEAT FINDING Yes 6. RECOMMENDATION We recommend the Authority strengthen its controls over the Public and Indian Housing Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. 7. QUESTIONED COST Cannot be determined. 8. VIEWS OF RESPONSIBLE OFFICIAL In January 2011, NYCHA implemented the Siebel Customer Relationship Management (CRM) system, which included digital file storage and an online application process, which replaced our previous paper application process. Any applications in process from that date onward were subject to document scanning and documentation was stored digitally. Any applications processed prior to this date were kept in a paper format and stored at the development, where the applicant was certified or where the tenant resides. If a tenant family transferred to another development, the physical tenant folder and documents were sent to their new location. In June 2020, NYCHA sought to digitize all tenant folders; however, the cost of the project was determined to be prohibitive so the goal of digitizing the tenant folders was not realized. Any documents damaged or lost prior to 2011 cannot be recovered, including those impacted by Hurricane Sandy.

Corrective Action Plan

Finding Number 2023-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). Condition/Context The Authority received funding from the HUD. The Public and Indian Housing program is to provide and operate cost effective, decent, safe, and affordable dwellings for lower income families through an authorized local PHA. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: Eight eligibility forms were not provided (five missing application forms, one missing certifications information provided to the PHA forms and two missing Release form). These forms are required documentation to be maintained in the case files to support eligibility for Public and Indian Housing Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan In January 2011, NYCHA implemented the Siebel Customer Relationship Management (CRM) system, which included digital file storage and an online application process, which replaced our previous paper application process. Any applications in process from that date onward were subject to document scanning and documentation was stored digitally. Any applications processed prior to this date were kept in a paper format and stored at the development, where the applicant was certified or where the tenant resides. If a tenant family transferred to another development, the physical tenant folder and documents were sent to their new location. In June 2020, NYCHA sought to digitize all tenant folders; however, the cost of the project was determined to be prohibitive so the goal of digitizing the tenant folders was not realized. Any documents damaged or lost prior to 2011 cannot be recovered, including those impacted by Hurricane Sandy. Action Date September 6,2024 Final Implementation September 6,2024 Name And Phone Number Of Person Responsible for Implementation Sylvia Aude Senior Vice president Office of the Senior Vice President for Public Housing Operations Tenancy Administration +1-212-306-3921

Categories

Questioned Costs HUD Housing Programs Eligibility

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $1.60B
14.850 Public and Indian Housing $1.32B
14.872 Public Housing Capital Fund $782.38M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $158.10M
14.U01 Covid-19-Ehv-Emergency Housing Vouchers $100.83M
14.218 Community Development Block Grants/entitlement Grants $44.09M
97.036 Covid-19-Disaster Grants - Public Assistance (presidentially Declared Disasters) $41.44M
14.879 Mainstream Vouchers $3.84M
14.888 Lead-Based Paint Capital Fund Program $3.02M
14.269 Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (cdbg-Dr) $2.94M
14.870 Resident Opportunity and Supportive Services - Service Coordinators $173,219
97.047 Bric: Building Resilient Infrastructure and Communities $162,522
14.896 Family Self-Sufficiency Program $103,959
97.045 Cooperating Technical Partners $12,000
97.039 Hazard Mitigation Grant $-1.72M