Finding 518735 (2024-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-01-10

AI Summary

  • Core Issue: The Authority failed to provide necessary documentation for one tenant file, specifically lacking third-party verification for full-time student status and income reporting.
  • Impacted Requirements: Compliance with HUD regulations and the Authority's administrative plan regarding income verification and student status documentation.
  • Recommended Follow-Up: Management should strengthen controls for in-house and external housing specialists to ensure all required documents are collected and properly maintained.

Finding Text

2024-001 – HCV Eligibility Federal Agency: Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: GA006, 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). Per the Authority's administrative plan, income support must fall under one of the acceptable verification methods and full-time student statuses must have third party verification or a documented review. Condition: During the testing of 40 Moving to Work Demonstration Program Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted. Of the tenant files provided, there was 1 instance where the Authority was unable to provide third-party verification for full-time student status as well as reported and excluded income for the tenants and dependents. Questioned costs: N/A Context: Out of 40 files, 1 file did not contain required documentation as noted above. Cause: The Authority failed to provide adequate support to ensure compliance with HUD regulations as well as its administrative policy. Effect: The Authority does not have adequate procedures in place to ensure that the files maintain adequate support. Repeat Finding: No Recommendation: We recommend management to implement controls over in-house and external housing specialists to ensure all documents are obtained by tenants and maintained in the tenant files. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Housing and Urban Development 2024-001 - Eligibility Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that management implement controls over in-house and external housing specialists to ensure all documents are obtained by tenants and maintained in the files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As it relates to the 2024-001 Eligibility finding, Atlanta Housing (AH) reached out to the Corbin family in one last attempt to gather the required information to address the participant’s file. The family has until Close of Business on Monday, November 4, 2024 to resolve the issues identified in the file. Failure to provide the required documents by the date noted will result in AH beginning the pro-termination process for failure to provide the required documentation to complete the recertification. Additionally, if the family does not comply, AH will correct the recertification, remove the educational exclusion, reinstate the income from the excluded income, and repay the Housing Assistance Payment via a Tenant Payment Agreement with the family. Name(s) of the contact person(s) responsible for corrective action: (1) Tracy D. Jones, Senior Vice President, Housing Choice Voucher Program Recommended correction: Ensure that management implement controls over in-house and external housing specialists to ensure all documents are obtained by participants. Corrective Actions: AH has a comprehensive six-week onboarding training program for all new hires that provides an overview of Housing Choice's end-to-end eligibility process for program participants. This training includes collecting, reviewing, and processing documentation necessary to complete the required certification for all programs. • Additionally, AH has a Quality Assurance program in place, which ensures that 100% of all new applicants' files are reviewed, along with 50% of all annual and interim recertifications. • AH employs a Quality Control Management System to track all corrections and manage the closure of those corrections effectively. • Furthermore, AH has utilized data from the Quality Control Management System to develop refresher training for current staff. Preventive Actions: • The Quality Assurance Manager will use the HCVP Operational procedures to conduct random reviews of previously audited and/or corrected files to ensure consistency and accuracy. • Key responsibilities include: ➢ Ensuring that the required checklist is utilized for each processed file. ➢ Reviewing the files of newly onboarded hires at a higher percentage than those of current staff. ➢ Providing a report on any abnormalities and documenting files of staff members who may require additional attention and one-on-one training. *Note: The issue for the file in question was addressed during the Audit and resolved November 4, 2024.

Categories

Eligibility HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1095177 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $361.05M
14.889 Choice Neighborhoods Implementation Grants $2.45M
14.871 Section 8 Housing Choice Vouchers $2.38M
14.879 Mainstream Vouchers $1.24M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $587,220
14.896 Family Self-Sufficiency Program $393,590