Finding 50458 (2022-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 45206
Organization: City of West Allis (WI)

AI Summary

  • Core Issue: The City failed to enforce Housing Quality Standards (HQS) for units under HAP contracts, leading to noncompliance with federal requirements.
  • Impacted Requirements: The City did not ensure timely correction of life-threatening HQS deficiencies within 24 hours and other deficiencies within 30 days, as mandated by 24 CFR sections 982.158(d) and 982.404.
  • Recommended Follow-Up: The City should review and strengthen its internal control systems and procedures to prevent future noncompliance with HQS enforcement requirements.

Finding Text

2022 ? 001: Housing Quality Standards (HQS) Enforcement Federal Agency: Housing Choice Voucher Program Federal Program Name: U.S. Department of Housing and Urban Development Assistance Listing Number: 14.871 Federal Award Identification Number and Year: WI201VO2022 Award Period: January 1, 2022 ? December 31, 2022 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (HQS), the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family?s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our testing, we noted the City failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known ? Undeterminable; Likely - Undeterminable Context: From a sample of nine (9) program participant files selected for testing and three (3) program participant files where the unit failed inspection and the HAP was not appropriately abated. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The City's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 982.158(d) and 982.404 related to the HQS enforcement. Repeat Finding: Yes; 2021-002 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of HQS enforcement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PHA is currently finalizing a contract with a 3rd party contractor to perform the required HQS inspections. They anticipate that outsourcing the inspection work will lessen the workload on PHA staff to allow program staff to focus their efforts on improving overall program compliance, including HQS enforcement procedures. As the contract arrangement is rolled out staff will review procedures between inspectors and PHA staff to ensure proper communication and clear procedures are in place as they relate to enforcement actions. PHA staff also will implement a new standard procedure in which the Housing Coordinator will check a list of units with failed or incomplete inspection records against the payment batch report prior to sending the batch to Finance to issue the HAP payments. PHA Supervisory Staff have also requested more detailed information on the audit results to help them further analyze the 3 specific cases where customers were issued HAP payments despite a failed inspection. This will help supervisory staff conduct a more thorough review and consider additional procedural changes. Additionally, the Finance Department suggests the PHA engage its software vendor or a peer agency to review functionality in the software to determine whether additional features could be employed in the software to prevent a HAP payment on a unit with a failed inspection, for example. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: 3/31/2024

Categories

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 50459 2022-002
    Material Weakness Repeat
  • 50460 2022-003
    Significant Deficiency
  • 50461 2022-004
    Significant Deficiency Repeat
  • 50462 2022-005
    Material Weakness
  • 50463 2022-001
    Material Weakness Repeat
  • 50464 2022-002
    Material Weakness Repeat
  • 50465 2022-003
    Significant Deficiency
  • 50466 2022-004
    Significant Deficiency Repeat
  • 50467 2022-005
    Material Weakness
  • 626900 2022-001
    Material Weakness Repeat
  • 626901 2022-002
    Material Weakness Repeat
  • 626902 2022-003
    Significant Deficiency
  • 626903 2022-004
    Significant Deficiency Repeat
  • 626904 2022-005
    Material Weakness
  • 626905 2022-001
    Material Weakness Repeat
  • 626906 2022-002
    Material Weakness Repeat
  • 626907 2022-003
    Significant Deficiency
  • 626908 2022-004
    Significant Deficiency Repeat
  • 626909 2022-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $4.35M
95.001 High Intensity Drug Trafficking Areas Program $2.62M
14.218 Community Development Block Grants/entitlement Grants $1.13M
14.871 Section 8 Housing Choice Vouchers $419,804
16.754 Harold Rogers Prescription Drug Monitoring Program $357,573
16.838 Comprehensive Opioid Abuse Site-Based Program $207,990
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $166,021
16.922 Equitable Sharing Program $114,995
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $65,066
93.268 Immunization Cooperative Agreements $50,247
10.561 Community Development Block Grants/entitlement Grants $41,956
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $35,255
14.239 Home Investment Partnerships Program $21,398
93.136 Injury Prevention and Control Research and State and Community Based Programs $19,563
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $18,921
93.991 Preventive Health and Health Services Block Grant $17,469
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $14,345
16.607 Bulletproof Vest Partnership Program $12,886
20.616 National Priority Safety Programs $11,901
16.710 Public Safety Partnership and Community Policing Grants $9,641
93.994 Maternal and Child Health Services Block Grant to the States $8,815
16.034 Coronavirus Emergency Supplemental Funding Program $8,128
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $7,534
10.528 Usda Wic Telehealth Evaluation Collaborative (b) $5,499
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $4,849
16.001 Law Enforcement Assistance_narcotics and Dangerous Drugs_laboratory Analysis $2,461
20.600 State and Community Highway Safety $1,324
93.069 Public Health Emergency Preparedness $109
14.U01 Section 8 Fss Escrow Forfeiture Account $74
93.103 Food and Drug Administration_research $-129