Finding 499582 (2023-002)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-09-30
Audit: 322442
Auditor: Marcum LLP

AI Summary

  • Core Issue: The PHA failed to properly verify and document tenant income, assets, and deductions, leading to inaccuracies in housing assistance calculations.
  • Impacted Requirements: Annual reexaminations and third-party verifications were not consistently completed as mandated by HUD regulations.
  • Recommended Follow-Up: Strengthen policies and procedures to ensure all necessary documentation and annual recertifications are properly maintained in tenant files.

Finding Text

2023-002 – ELIGIBILITY – ELIGIBILITY FOR INDIVIDUALS Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development ALN 14.871 – Section 8 Housing Choice Vouchers CRITERIA The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: (i) Reported family annual income; (ii) The value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income. (2 CFR 982.516 (a)) (1) As a condition of admission to or continued assistance under the program, the PHA shall require the family head, and such other family members as the PHA designates, to execute a HUD-approved release and consent form (2 CFR 982.516(g)) CONDITION As a result of our testing, we identified the following: • Two instances of incorrect or incomplete verifications of income, assets, or deductions. • Two instances of incorrect payment standards used. • Two instances of utility allowance miscalculations. • One certification that was not completed timely. CAUSE The Authority's system of obtaining and documenting third-party verifications of tenant’s income, assets, or deductions was not sufficient. EFFECT The Authority did obtain proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby housing assistance payments. QUESTIONED COSTS None Noted. CONTEXT The Authority leased approximately 320 vouchers through the Housing Choice Voucher Program throughout the year. We selected a sample of 25 participant files. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend policies and procedures are strengthened to ensure all proper documentation and annual recertification are maintained in all tenant files to document eligibility. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan. SECTION IV – SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS No prior audit findings.

Corrective Action Plan

Response: Ensure that existing filing errors are corrected and to ensure that future filing accuracy is demonstrated. Vernon Housing is implementing the following: Vernon Housing has an existing quality control program to ensure that all HCV files are complete and up to date. In addition, Vernon Housing has reorganized itself with new staff being placed during the mid-year of FY23 and current. This Housing Program Manager position centralizes Housing program oversight with expertise necessary for a successful quality control system. The Agency fiscal year 2023 audit first noted the need for improved quality control Housing Choice voucher program and filing. The sample errors pointed out during the audit have been corrected and reviewed with associated personnel. Going forward since the beginning of CY 2024 the Housing program manager has reviewed all interims along with annual certifications completed by the direct reports for compliance and filing accuracy. A structured filing system has been identified for all staff personnel to follow and be assessed during the quality control review process. A monthly quality control schedule has been implemented to report to upper management during the department closing process. Management will continue to require staff to attend training and obtain the PH/HCV Specialist Certification as a mandatory job requirement. Management will continue efforts to standardize tenant files, perform supervisory and compliance file reviews and hold staff accountable for failure to adhere to the governing rules and regulations for file compliance. HCV Program staff will continue to use file review checklists when performing Recertification procedures, which require the review of Lease Addendums to ensure that the proper documentation is in the file. These are ongoing tasks. The Housing Program Manager will be responsible for these tasks. Planned Implementation Date of Corrective Action: October 2024 Person Responsible for Corrective Action: Shenoa Steves-Housing Program Manager

Categories

HUD Housing Programs Eligibility Significant Deficiency

Other Findings in this Audit

  • 1076024 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $3.75M
14.872 Public Housing Capital Fund $1.17M
14.850 Public Housing Operating Fund $675,879
14.888 Lead-Based Paint Capital Fund Program $2,540