Finding 504877 (2024-002)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2024

Accepted

2024-11-07

Audit: 327628

Organization: North Providence Housing Authority (RI)

Auditor: Marcum LLP

AI Summary

Core Issue: The Authority failed to properly assess rent reasonableness in ten cases, violating HUD requirements.
Impacted Requirements: The PHA must determine and redetermine reasonable rent before lease approval and rent increases.
Recommended Follow-Up: Implement a recertification checklist to ensure all necessary documentation is collected for tenant files.

Finding Text

024-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 / 14.879 – Housing Voucher Cluster CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507) CONDITION We identified ten instances in which the Authority was required to perform an assessment to determine if the rent requested by the landlord is reasonable. In all instances, the Authority did not perform this rent reasonableness assessment properly. AUSE The Authority’s system of internal control over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 40 from a population of 276. This was not a statistically valid sample. REPEAT FINDING See finding 2023-002 RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

Section III – Federal Award Findings and Questioned Costs 2024-002-Special Tests & Provisions: Rent Reasonableness Material Weakness/Material Noncompliance Corrective Action: The North Providence Housing Authority hired an outside company to perform yearly rent reasonableness studies. Nelrod has given us the tools to perform these studies fast and efficiently with the use of their software program. Additionally, due to being a small housing authority, with only one HCV staff member, we have hired an HCV Assistant to help the HCV Coordinator in obtaining all information needed to comply with HUD’s regulations. Planned Implementation Date of Corrective Action: Immediately Planned Implementation Date of Corrective Action: Eileen Reyes/Michael McMahon/Cheryl Lonardo

Other Findings in this Audit

504875 2024-001

Significant Deficiency Repeat
504876 2024-001

Significant Deficiency Repeat
504878 2024-002

Material Weakness Repeat
1081317 2024-001

Significant Deficiency Repeat
1081318 2024-001

Significant Deficiency Repeat
1081319 2024-002

Material Weakness Repeat
1081320 2024-002

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
14.871	Section 8 Housing Choice Vouchers	$2.52M
14.850	Public Housing Operating Fund	$590,018
14.872	Public Housing Capital Fund	$533,662
14.879	Mainstream Vouchers	$416,888
14.896	Family Self-Sufficiency Program	$74,718