Finding 515781 (2024-007)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-19

AI Summary

  • Core Issue: The Commission lacks adequate internal controls for applying tenant utility allowances, leading to noncompliance with federal requirements.
  • Impacted Requirements: The Commission must establish and review utility allowances based on consumption and rates, as outlined in various federal regulations.
  • Recommended Follow-Up: Implement processes to ensure accurate application of utility allowances and compliance with program requirements.

Finding Text

2024 – 007 – PBRA/MOD – Utility Allowances Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner must (a) establish or ensure tenant utility allowances based on utility consumption and rate data for various sized units, structure types, and fuel types, (b) make an annual review of tenant utility allowances to determine their reasonableness, and (c) adjust the allowances, when appropriate (24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure utility allowances were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 6 exceptions: 6 files where the utility allowance on the 50058/50059 did not match the approved utility allowance Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over utility allowances. Effect: The Commission is not in compliance with program requirements over utility allowances. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct utility allowance is reflected on the HUD-50059. Management will also ensure that, going forward, site staff review the HUD-50059 utility allowance amounts for accuracy against the approved rent schedule. Additionally, Pratum will ensure that any certifications completed in advance of the Gross Rent Increase are corrected as needed to accurately reflect the correct utility allowance on the HUD-50059. HRD will review and update utility allowances currently in use, comparing them against the latest HUD-approved MOD Rehabilitation gross rent schedule. HRD and HOC Compliance team will develop or update policies and procedures to ensure that utility allowances are verified and updated as required by HUD. The training manager will conduct training sessions for relevant staff members on the utility allowance requirements and how to update them in HRD’s system of record database. As a preventive action, HRD’s management will establish a quarterly file review procedure to ensure that the utility allowances align with the HUD utility allowance approval. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC, Ali Ozair, Vice President of Property Management with HOC and Lynn Hayes, Vice President of Housing Resources Division with HOC. Planned completion date for corrective action plan: Pratum has immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. HRD has immediately implemented and will have the corrections to the impacted and future files completed by December 31, 2024.

Categories

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 515771 2024-001
    Material Weakness Repeat
  • 515772 2024-002
    Significant Deficiency
  • 515773 2024-001
    Material Weakness Repeat
  • 515774 2024-002
    Significant Deficiency
  • 515775 2024-001
    Material Weakness Repeat
  • 515776 2024-002
    Significant Deficiency
  • 515777 2024-003
    Material Weakness Repeat
  • 515778 2024-004
    Material Weakness Repeat
  • 515779 2024-005
    Significant Deficiency Repeat
  • 515780 2024-006
    Material Weakness
  • 515782 2024-008
    Significant Deficiency
  • 515783 2024-003
    Material Weakness Repeat
  • 515784 2024-004
    Material Weakness Repeat
  • 515785 2024-005
    Significant Deficiency Repeat
  • 515786 2024-006
    Material Weakness
  • 515787 2024-007
    Material Weakness
  • 515788 2024-008
    Significant Deficiency
  • 1092213 2024-001
    Material Weakness Repeat
  • 1092214 2024-002
    Significant Deficiency
  • 1092215 2024-001
    Material Weakness Repeat
  • 1092216 2024-002
    Significant Deficiency
  • 1092217 2024-001
    Material Weakness Repeat
  • 1092218 2024-002
    Significant Deficiency
  • 1092219 2024-003
    Material Weakness Repeat
  • 1092220 2024-004
    Material Weakness Repeat
  • 1092221 2024-005
    Significant Deficiency Repeat
  • 1092222 2024-006
    Material Weakness
  • 1092223 2024-007
    Material Weakness
  • 1092224 2024-008
    Significant Deficiency
  • 1092225 2024-003
    Material Weakness Repeat
  • 1092226 2024-004
    Material Weakness Repeat
  • 1092227 2024-005
    Significant Deficiency Repeat
  • 1092228 2024-006
    Material Weakness
  • 1092229 2024-007
    Material Weakness
  • 1092230 2024-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.188 Housing Finance Agencies (hfa) Risk Sharing $315.42M
14.267 Continuum of Care Program $4.11M
14.195 Project-Based Rental Assistance (pbra) $3.69M
14.879 Mainstream Vouchers $2.03M
14.871 Section 8 Housing Choice Vouchers $1.85M
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $768,888
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $429,791
14.896 Family Self-Sufficiency Program $367,956
14.269 Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (cdbg-Dr) $134,147
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $67,225
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $30,770