Finding 526836 (2024-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-13

AI Summary

  • Core Issue: 18 out of 200 tenant files (9%) were noncompliant, with issues like late reexaminations and missing income verification.
  • Impacted Requirements: Compliance failures violate federal regulations and internal policies, risking financial penalties and funding loss.
  • Recommended Follow-Up: Prioritize overdue reexaminations and enhance training for occupancy specialists to improve compliance monitoring.

Finding Text

Finding 2024-001 - Moving To Work Demonstration Tenant Files - Eligibility - Internal Control over Tenant Flies - Noncompliance and Significant Deficiency Moving To Work Demonstration - Subsidy ALN 14.881 Condition & Cause: Our review of two hundred (200) Moving To Work tenant files found that eighteen (18) files were noncompliant, representing 9% of our sample. Some files had multiple compliance issues. Specifically, we identified: • Thirteen (13] files where the annual reexamination was completed or made effective at least two months past the due date. • Four (4) files lacking proper verification of income or deductions. • Three (3) files with miscalculations of annual Income. • Four (4) files missing the EIV. • One (1) file processed for annual reexamination without tenant involvement. Using extrapolation, we concluded that the potential misstatement of subsidy from income miscalculations is immaterial to the financial statements. Criteria: Compliance requirements are outlined in the Code of Federal Regulations, the Housing Authority's Admissions and Continued Occupancy Policy (ACOP), Administrative Plan, Moving To Work (MTW) Plan, and specific HUD guidelines for documenting and maintaining Public Housing and Housing Choice Voucher tenant files. Effect: Deficiencies in tenant files can result in lost rental income due to late reexaminations, along with potential overpayments or underpayments by tenants stemming from inaccurate rent determinations. Ongoing noncompliance may also draw scrutiny from regulatory bodies, increasing the risk of financial penalties or loss of funding for the MTW program. Recommendation: We recommend that the Agency identify the annual recert1fications that are past or near due and complete these reexaminations. We also recommend that the Agency continue their monitoring and review of the Moving To Work files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Questioned Costs: None Repeat Finding: Yes Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

2024-01 Audit Finding/Plan of Action As requested, the Lexington Housing Authority (LHA) proposes this corrective plan of action to address a finding and other deficiencies found during an audit conducted by Rector, Reeder & Lofton PC, onsite at LHA September 16-20, 2024. Specifically, those deficiencies include: • Thirteen (13) files where the annual reexamination was completed or made effective at least two months past the due date. • Four (4) files lacking proper verification of income or deductions. • Three (3) files with miscalculationsof annual income. • Four (4) files missing the EIV. • One (1) file processed for annual reexamination without tenant involvement. LHA proposes the following to address the finding and deficiencies. - LHA will require training for each Housing Management Specialist (HMS) to review rent calculation, income verification, deductions and EIV file documentation. - Like other employers nationally, LHA is challenged with staffing issues, with a turnover rate of 84% for new hire HMS. To address staffing LHA will: • Advertise open positions online, on social media and in the local newspaper. • Evaluate incentives that will allow LHA to retain staff. • Allow over-time on an as-needed basis to complete and process certifications. • Offer new HMS pay beyond the minimum position classification scale. Further, LHA housing management staff will adhere to the following procedures to facilitate timely completion of annual certifications. - HMS staff will continue utilize in-person interviews and mail (via USPS and email) to complete needed documentation for annual certifications. - HMS staff may utilize electronic signature to attain required signatures when necessary. - Periodically housing managers will run the certification audit report to be shared with the Chief Operating Officer to monitor the status of in-progress and upcoming certifications. - LHA's compliance coordinator will complete QC reviews of 50% or 457 public housing files during FY2025. The compliance coordinator has undergone several training workshops and staff-shadowing during 2024 and is adequately trained to complete this task. - LHA will evaluate the possibility of securing a third-party to assist in timely completion of annual recertifications. LHA staff will apply these procedures as outlined to mitigate this finding to ensure compliance and proper documentation of future certifications. Contact Person: Andrea Wilson, Chief Operating Officer Anticipated Completion Date: June 30, 2025

Categories

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

Other Findings in this Audit

  • 526837 2024-001
    Significant Deficiency Repeat
  • 1103278 2024-001
    Significant Deficiency Repeat
  • 1103279 2024-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $30.12M
14.879 Mainstream Vouchers $1.25M
14.871 Section 8 Housing Choice Vouchers $786,250
14.870 Resident Opportunity and Supportive Services - Service Coordinators $245,029
14.238 Shelter Plus Care $239,510
14.267 Continuum of Care Program $136,787