Finding 499798 (2023-001)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-09-30

AI Summary

  • Core Issue: Participant files lack necessary documentation to prove eligibility for the Moving to Work program.
  • Impacted Requirements: Federal document retention policies are not being followed, leading to potential overpayments.
  • Recommended Follow-Up: Centralize eligibility determinations to improve oversight and ensure compliance with program procedures.

Finding Text

2023-001 – Eligibility - Moving to Work Demonstration Program - 14.881 Material Weakness and Material Noncompliance Statement of Condition and Criteria Participant files were missing, incomplete or insufficient to substantiate eligibility determinations. PHA’s are required to maintain and retain documentation in accordance with federal document retention policies to substantiate the ongoing eligibility of participants. Cause Lack of effective oversight of certification procedures conducted at site offices, including outside contracted management agencies. In addition, conversion to electronic workpaper retention, as well as system conversions resulting in loss of data. Effect or Potential Effect Potential overpayment of housing assistance. Question Costs Not determined. Context A sample of 45 files were selected to audit program eligibility from a population of 2,766. The test found 16 files did not pass audit inspection due to missing significant supporting documentation to support the calculation of housing assistance. Our sample was not a statistically valid sample. Recommendation We recommend the Authority centralize eligibility determinations to assist with enforcement and quality control review of program procedures. This would include removing responsibilities from both external and internally managed sites to better align staff and program responsibilities. Management’s Response Management agrees with the finding and corrective action is in progress as detailed in the Corrective Action Plan.

Corrective Action Plan

Corrective Action The initial eligibility determinations are currently handled by the HCV department and are centralized. It has been determined that considerable investment in staff training has been made during the past twelve months. As a result, there has been staff turnover, some at the decision of TGHA, and some at the decision of staff. Initial eligibility is currently being restructured with an emphasis on new admissions. All procedures and processes are being evaluated for accuracy, with emphasis on the noted area of noncompliance and includes a complete review and update to the Administrative Plan. There will be increased staff training and file review. In July 2024, TGHA transitioned project-based files from a property management team to the Housing Choice Voucher Department. The files had not been electronically stored. Evidence pointed to deficiencies in file maintenance. TGHA has hired temporary staff for an extended period to focus on file organization and to correct documentation deficiencies. All HCV staff have completed Rent Calculation courses provided by NAHRO or Nan McKay during the fiscal year. There have been two managers hired for the department, one exclusively for project-based vouchers. Both attended NAHRO supervisory training in September. There will be an intensive focus on program integrity throughout the programs, including staff capability, training and monitoring. TGHA has contracted with a professional recruiter to assist in hiring a Director of the HCV and MTW programs. Recertification transactions will be monitored on a monthly basis. This will include validation of calculations and verification of correct documentation. It is anticipated that TGHA files will be fully in order by July 2025.

Categories

Eligibility HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 499799 2023-002
    Significant Deficiency
  • 1076240 2023-001
    Material Weakness
  • 1076241 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $26.98M
14.871 Section 8 Housing Choice Vouchers $1.71M
14.896 Family Self-Sufficiency Program $211,176
14.879 Mainstream Vouchers $189,688