Finding 2024-001
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs
Assistance Listing Number: 14.871, 14.879 and 14.EHV
Noncompliance - N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No
Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions
Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority's files and on discussions with management, the Authority did not properly abate one (1) out of thirty-seven (37) annual failed inspections selected for testing.
Context: The Authority did not properly abate one (1) out of thirty-seven (37) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b).
Our sample size is statistically valid.
Known Questioned Costs: $398
Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance with Notice PIH 2021-14(HA).
Effect: The Housing Voucher Cluster is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections.
Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.
Views ofresponsible officials and planned corrective action:
Of the Thirty-Seven (37) tenant files audited, one (1) tenant file contained a deficiency--- the file did not contain adequate verification of the abatement cure request date justifying the HACCC's subsequent cancellation of this abatement after the deficiencies were verified as corrected.
The HACCC discovered a contributing factor for this deficiency and identified a plan to ensure compliance with this requirement which is detailed below.
HUD requires HACCC's Housing Choice Voucher program to abate (permanently withhold) housing assistance payments no later than the first of the month following the specified correction period (including any approved extension) when HQS deficiencies are discovered during biennial HQS inspections of subsidized units. To improve housing opportunities to families with vouchers and support landlord retention on our programs, the HACCC (in accordance with applicable regulations) offers to end the period of HAP abatement "effective on the earlier of the day the unit passes inspection or the date the correction was reported completed' as a courtesy.
In this case, the unit failed inspection for non-life threatening deficiencies (ex. overgrown grass) on 6/20/2023. The deficiencies were not corrected prior to the reinspection which took place on 7/18/2023, prompting the placement of a HAP abatement on 7/26/2023 to withhold all HAP payments effective 8/1/2023 on. A reinspection was requested and the unit passed inspection in August. On 8/31/23 the abatement was subsequently cancelled in the HACCC's software and a memo was entered indicating that the landlord had requested the abatement cure reinspection prior to the abatement effective date of 8/1/23. However, it was discovered that the necessary verification of this abatement cure request was not attached
to the tenant record. Due to the HACCC's inability to reproduce verification of the request date (being earlier than the day the unit passed inspection), the HACCC agrees with this finding.
To ensure compliance with this requirement, the Internal HCV Inspection Procures will be updated to include systems for ensuring that necessary verification of any abatement cure request date is stored. A File Memo containing a timeline and necessary verification ofrequest date will be submitted to a manager for approval any time an abatement is ended or cancelled. The manager will be responsible for storing the executed File Memo and verification in the tenant file.
The Authority has recognized the deficiencies in the Housing Voucher Cluster and has implemented internal control procedures that will ensure compliance of federal regulations. Ingrid Layne, Director of Assisted Housing, will be responsible to implement this corrective action by March 31, 2025.