Finding 519840 (2024-001)

Finding: 2024-001 Program Name: Moving to Work (ALN #14.881) Federal Awarding Agency: Department of Housing and Urban Development Compliance Requirement: Eligibility Type of Finding: Material Weakness; Material Noncompliance Qualification Criteria: Per 24 CFR section 982.516, the Authority must reexamine family income and composition at least once every two years and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification. Condition: Of the 52 Housing Choice Voucher tenant files tested, the following items were noted: • 48 instances of certifications not completed timely • 17 instances where the file did not contain income support or the support in the file did not agree to the amount used on the certification (the files were later updated with the correct income for 6 of these tenants) • 5 instances where an incorrect payment standard was used • 11 instances where the standard medical deduction did not match the deduction allowed per the Administrative Plan • 2 instances where inspections were not completed within the last 2 years • 7 instances where the incorrect utility allowance was used • 1 file was missing a citizenship declaration for a household member. Cause: During fiscal year 2024, the Authority had employee turnover resulting in a backlog of recertifications. Because payments to landlords on the annual HAP contracts were set to expire, the Authority rolled forward the tenant’s prior year form HUD-50058 Family Report without updating family income and composition. In addition, the shortage of staff resulted in errors noted above in calculations. Effect: The Authority was not in compliance with the eligibility compliance requirements for the year ended June 30, 2024. Failure to perform income recertifications and errors in calculating deductions and allowances could result in improper housing assistance payments. Auditor Recommendation: We recommend the Authority perform a review of all tenant files to ensure income has been appropriately recertified and housing assistance payments are accurate. Questioned Costs: Undeterminable. Management’s Response: LMHA implemented in March of 2024, a comprehensive plan to resolve the backlog of recertifications that necessitated the roll forward of tenant’s prior year form HUD-50058 family report without updating family income and composition. First and foremost, representing the rolling forward of the tenant’s HUD-50058 as a biennial recertification has been discontinued. Housing Choice Voucher Department staff has implemented training of Housing Specialists and other staff to ensure biennial recertification and use of HUD-50058 Type 2 (“Annual Recertification”) will now be compliant. LMHA continues its contractual relationship with Nan McKay & Associates to assist with the recertification process and resolve the backlog of 50058 recertifications. LMHA has restructured workflows to provide efficiencies and accountability that will promote compliance. LMHA continues to work with various HUD departments and personnel to assess noncompliance and how to move forward. LMHA engaged its Financial Auditor, Cherry Bekaert, to review the Housing Choice Voucher Program for process, compliance, and internal control. From that collaborative process, in July 2024, LMHA was provided a comprehensive report including recommendations to improve the HCV program processes in all phases which LMHA is actively incorporating into everyday procedures.