Finding 50421 (2022-003)

Material Weakness
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2023-07-30

AI Summary

  • Core Issue: The Authority failed to conduct timely Housing Quality Standards (HQS) inspections, risking payments for substandard housing.
  • Impacted Requirements: Noncompliance with 24 CFR 982.158 and 982.405, including missed inspection deadlines and inadequate record-keeping.
  • Recommended Follow-Up: Improve internal controls to ensure timely inspections and proper documentation; address deficiencies in participant files and overall procedures.

Finding Text

Finding Reference: 2022-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Criteria Pursuant to 24 CFR 982.158 and 982.405, the Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and must also conduct quality control re-inspections. The PHA must prepare and maintain a unit inspection report for at least three years. To provide relief during the coronavirus pandemic, HUD waived the biennial inspections through December 31, 2021. The Authority must resume biennial inspections by December 31, 2021. The Authority must conduct all delayed biennial inspections from calendar year 2020 as soon as reasonably possible but no later than June 30, 2022 and must conduct all delayed biennial inspections from calendar year 2021 as soon as reasonably possible but no later than December 31, 2022. Condition From a total population of about 15,000 tenants for the fiscal year ended September 30, 2022, we selected a statistically valid sample of one monthly subsidy payment for each of 62 selected tenants, and identified four tenants whose HQS inspections were completed past the due dates and two tenants whose HQS inspection reports were not provided for review. Cause of Condition The Authority?s internal control procedures were not sufficient to ensure that all HQS inspections are completed within the specified due dates and that all related inspection records are properly filed. Effect The Authority is not in compliance with the HQS inspection requirements. The Authority may be paying Housing Assistance Payments (HAPs) to property owners whose units have inadequate housing quality. Questioned Costs Known questioned costs of $41,034 represent HAPs for the months for which compliance with housing assistance payments are questioned. Projecting the known questioned costs from the sample of 62 participants that totaled $1,256,435 in HAPs to the total HAPs of $347,949,755 for the year, results in likely questioned costs of $11,363,796. Identification of Repeat Finding This is not a repeat finding in the immediately prior audit. Recommendation The Authority should correct the deficiencies noted in the sampled participant files and consider the impact of the audit results over the entire population. In addition, the Authority should revisit its procedures, systems and controls to ensure the required HQS inspections are completed in a timely manner, and to strengthen its record retention and filing systems. View of Responsible Officials and Planned Corrective Action See separately prepared Corrective Action Plan.

Corrective Action Plan

Reference Number: 2022-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority?s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual inspections. Since outsourcing the programmatic functions of the HCV program to a third-party contractor. The Authority acknowledges that more progress in this area is required and continues to work diligently with the third-party HCV contractor to ensure this occurs. The Authority will continue to reinforce its current oversight process to ensure HQS inspections are performed in accordance with HUD requirements. The Authority adopted a series of HUD waivers following the COVID-19 pandemic, one of which HQS-5, under Notice PIH 2021-14, allowing the Authority to waive the completion of HQS Inspections through December 31, 2021. The Authority resumed the completion of HQS Inspections and was required by HUD to complete all delayed inspections by December 31, 2022. During fiscal year 2022, the Authority had inspections not completed in a timely manner, however, was not out of compliance as waivers were in place. The Authority is committed to ensuring all units under contract are beyond safe, sanitary, and decent in accordance with HQS requirements and the Authority's Administrative Plan. The Authority uses the Emphasys Elite software to check against HUD's PIH Information Center (PIC) system to identify units with outstanding Housing Quality Standards (HQS) Inspections. The Authority has scheduled HQS Inspections for the units identified to be out of compliance. Some key strategies and controls in place are as follows: ? Review the report of outstanding HQS Inspections on a weekly basis. ? Schedule outstanding HQS Inspections in order of aging date. ? Conduct HQS Inspections prior to anniversary date of previously completed inspection. ? Running a monthly report of failed inspections and comparing them with future scheduled inspections to ensure a timely scheduling of the second inspection. ? Running a monthly report to identify units with two failed inspections to ensure all have been abated correctly. ? Implement weekly monitoring to ensure all units are properly abated and lifted timely when units pass inspections and contracts are properly terminated after being in abatement for 180 days without a cure. The Authority will continue to execute these sound procedures to prevent further findings related to inspections. The Authority has implemented a robust internal audit program starting fiscal year 2021- 22 and will continue to select annually a statistically significant random sample of actions completed by the HCV contractor to ensure that all actions are in compliance and files contain all required documentation. Although the HCV program subscribes to a quality control process, the Authority's internal audit program provides a method to reasonably understand the condition of the program as the Authority fully understands its responsibility to ensure the program complies to all applicable laws and regulations governing HCV operations. The HCV program is a part of our continuous monitoring process. Anticipated Implementation Date September 30, 2023 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractor Kendra Crawford, Director of Housing Operations

Categories

Questioned Costs HUD Housing Programs Material Weakness Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 50419 2022-002
    Material Weakness Repeat
  • 50420 2022-004
    Significant Deficiency Repeat
  • 50422 2022-003
    Material Weakness
  • 50423 2022-003
    Material Weakness
  • 626861 2022-002
    Material Weakness Repeat
  • 626862 2022-004
    Significant Deficiency Repeat
  • 626863 2022-003
    Material Weakness
  • 626864 2022-003
    Material Weakness
  • 626865 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $348.81M
14.850 Public and Indian Housing $11.40M
14.872 Public Housing Capital Fund $9.69M
14.871 Section 8 Housing Choice Vouchers - Covid-19 $4.94M
14.879 Mainstream Vouchers $3.95M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $718,283