Finding 501143 (2023-002)

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

AI Summary

  • Core Issue: Significant deficiencies in tenant file management for both Section 8 and Low Rent Public Housing programs, leading to noncompliance with HUD requirements.
  • Impacted Requirements: Failure to perform timely annual recertifications, lack of necessary documentation, and inadequate internal controls as per the Authority’s ACOP and HUD regulations.
  • Recommended Follow-up: The Authority should reassess and strengthen procedures for compliance, address identified deficiencies, and evaluate the impact on the entire tenant population.

Finding Text

2023-002 Eligibility Moving to Work Demonstration Program AL No. 14.881 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 18,300 of Section 8 Housing Choice Voucher and 2,300 Low Rent Public Housing tenants the following deficiencies were noted: Section 8 Housing Choice Voucher (a total of 40 tenants selected for testing): • Thirty-five files did not have annual recertifications performed during the year, • Nine files did not have 9886 release of information forms within 15 months of annual recertification, • Four files did not have an annual recertification performed with 12 months of the previous certification, • Three files did not have an inspection performed during the year • Three files did not have documentation necessary to verify the reported income, • Two files did not have a 214 declaration for a member of the household, and • Two files did not have documentation necessary to verify custody of dependents. Low Rent Public Housing (a total of 40 tenants selected for testing): • Fourteen files did not contain flat rent options forms, • Ten files did not have documentation necessary to verify the reported income, • Seven files did not have the annual recertification performed or documented, • Five files did not have a 214 declaration for a member of the household, • Three files did not have support necessary to verify income allowances, • Two files did not have 9886 release of information from within 15 months of the annual recertification, and • One file did not have annual recertifications performed within 12 months of the previous annual certification. Criteria: The Authority’s ACOP, Administrative Plan, 24 CFR 960.259, and 24 CFR 982.516 require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Context: The auditor randomly selected tenant files out of the population from each program as outlined, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of COVID-19 and did not have the available staff to follow the established internal controls to ensure proper compliance with regards to timely recertifications and collection of required HUD documentation to verify eligibility and calculate accurate housing assistance payments. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: Unknown. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: See Corrective Action Plan.

Corrective Action Plan

2023-002 Eligibility Moving to Work Demonstration Program AL No. 14.881 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 18,300 of Section 8 Housing Choice Voucher and 2,300 Low Rent Public Housing tenants the following deficiencies were noted: Section 8 Housing Choice Voucher (a total of 40 tenants selected for testing): • Thirty-five files did not have annual recertifications performed during the year, • Nine files did not have 9886 release of information forms within 15 months of annual recertification, • Four files did not have a annual recertification performed with 12 months of the previous certification, • Three file did not have an inspection performed during the year • Three files did not have documentation necessary to verify the reported income, • Two files did not have a 214 declaration for a member of the household, and • Two files did not have documentation necessary to verify custody of dependents. Low Rent Public Housing (a total of 40 tenants selected for testing): • Fourteen files did not contain flat rent options forms, • Ten files did not have documentation necessary to verify the reported income, • Seven files did not have the annual recertification performed or documented, • Five files did not have a 214 declaration for a member of the household, • Three files did not have support necessary to verify income allowances, • Two files did not have 9886 release of information form within 15 months of the annual recertification, and • One file did not have annual recertifications performed within 12 months of the previous annual certification. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected during the final quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that all HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the final quarter of 2024.

Categories

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

Other Findings in this Audit

  • 501142 2023-001
    Material Weakness Repeat
  • 501144 2023-003
    Material Weakness Repeat
  • 501145 2023-004
    Material Weakness Repeat
  • 501146 2023-005
    -
  • 501147 2023-001
    Material Weakness Repeat
  • 501148 2023-001
    Material Weakness Repeat
  • 501149 2023-001
    Material Weakness Repeat
  • 501150 2023-001
    Material Weakness Repeat
  • 501151 2023-001
    Material Weakness Repeat
  • 501152 2023-003
    Material Weakness Repeat
  • 501153 2023-004
    Material Weakness Repeat
  • 501154 2023-004
    Material Weakness Repeat
  • 1077584 2023-001
    Material Weakness Repeat
  • 1077585 2023-002
    Material Weakness Repeat
  • 1077586 2023-003
    Material Weakness Repeat
  • 1077587 2023-004
    Material Weakness Repeat
  • 1077588 2023-005
    -
  • 1077589 2023-001
    Material Weakness Repeat
  • 1077590 2023-001
    Material Weakness Repeat
  • 1077591 2023-001
    Material Weakness Repeat
  • 1077592 2023-001
    Material Weakness Repeat
  • 1077593 2023-001
    Material Weakness Repeat
  • 1077594 2023-003
    Material Weakness Repeat
  • 1077595 2023-004
    Material Weakness Repeat
  • 1077596 2023-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $236.73M
14.871 Section 8 Housing Choice Vouchers $11.01M
14.879 Mainstream Vouchers $6.18M
14.239 Home Investment Partnerships Program $4.36M
14.267 Continuum of Care Program $2.26M
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $1.02M
14.870 Resident Opportunity and Supportive Services - Service Coordinators $833,588
14.895 Jobs-Plus Pilot Initiative $266,217
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $194,601
14.191 Multifamily Housing Service Coordinators $188,859