Response to Finding 2023-003
The Authority generally concurs with the auditor’s findings and recommendations. To address
the finding related to inadequate documentation for rent reasonableness determinations, the
Authority will implement the following corrective actions:
1. Immediate and Ongoing Training:
• To ensure consistency, increase staff knowledge, and reduce errors, the Authority will conduct immediate training sessions for all relevant staff, followed by annual refresher training. These sessions will focus on the correct procedures for documenting rent reasonableness and the importance of maintaining accurate and complete records.
2. Enhanced Quality Control and Error Monitoring:
• The Authority will increase the frequency of quality control file reviews to identify errors promptly and address their root causes to prevent systemic issues.
• Errors will be tracked by type and by the staff member responsible, allowing for the identification of patterns. Additional training will be provided for common error types and to individuals who are frequently responsible for errors.
3. Comprehensive File Reviews:
• Quality reviews will be conducted on all files to ensure the presence of all required documents. It is anticipated that the initial comprehensive file review will take approximately one year to complete.
• After the initial review, files will be selected randomly for review according to an established quality control schedule. This ongoing review process will ensure continuous compliance and address any issues as they arise.
4. Responsibility for Document Collection:
• Each team member will be responsible for collecting any missing documents identified during the annual recertification, interim recertification, or change of unit processes. This accountability measure ensures that all necessary documentation is gathered and maintained consistently.
5. Adoption of a Digital Platform:
• As part of the corrective action, the Authority has adopted a digital platform that requires the completion of all necessary fields before a rent determination can be finalized. This platform will also retain all documentation used to determine rent reasonableness for at least two years, ensuring thorough and accessible records.
6. Increased Random Audits:
• Effective October 2024, random audits will be increased to monthly reviews to identify any discrepancies early and to ensure ongoing compliance with documentation requirements.
Name of the contact person responsible for corrective action: Deputy Executive Director
LaMonyka French
Completion Date: December 2024