Finding 540603 (2024-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-30

AI Summary

  • Core Issue: Significant deficiencies in internal controls were found in the eligibility processes for Section 8 and Low Rent Public Housing tenants.
  • Impacted Requirements: Compliance with HUD requirements for timely and accurate tenant file management is not being met, affecting eligibility and recertification.
  • Recommended Follow-Up: The Commission should review and improve procedures and controls to address identified deficiencies and ensure compliance across all tenant files.

Finding Text

2024-001 Eligibility Moving to Work Demonstration Program AL No. 14.881 Significant deficiency in internal control Other Matter to be Reported Under the Uniform Guidance Condition: Out of an approximate population of 4,700 of Section 8 Housing Choice Voucher and 220 Low Rent Public Housing tenants the following deficiencies were noted: Section 8 Housing Choice Voucher (a total of 40 tenants selected for testing): • Four files did not have annual recertifications performed during the year available, • Four files did not use the correct utility allowance, • One file did not have support necessary to verify income adjustments, • One file did not use the correct payment standard, • One file did not have support necessary to verify income exemptions, • Six files did not have documentation necessary to verify the reported income, • Seven files did not have a 214 declaration for a member of the household, and • Two files did not have documentation necessary to verify custody of dependent Low Rent Public Housing (a total of 20 tenants selected for testing): • One file did not contain a flat rent options form, • Two files did not have documentation necessary to verify the reported income, • One file did not have a 214 declaration for a member of the household, • One file did not have support necessary to verify income adjustments, • Two files did not have 9886 release of information from within 15 months of the annual recertification, and • Two files did not have an internal control document Criteria: The Commission’s ACOP, Administrative Plan, 24 CFR 960.259, and 24 CFR 982.516 require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Context: The auditor randomly selected tenant files out of the population from each program as outlined, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Commission is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Commission does not have adequate systems and controls in place to ensure all eligibility requirements are being followed. Effect: The Commission is not in compliance with all of the HUD requirements regarding eligibility and tenant recertification which could result in incorrect amount of rental assistance being provided. Questioned Costs: Unknown. Auditor Recommendations: The Commission should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Commission needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: See Corrective Action Plan.

Corrective Action Plan

GRHC Response & Corrective Action Plan The GRHC does not dispute the finding and acknowledges the deficiencies identified. Due to staff shortages and turnover, GRHC experienced challenges in maintaining consistent file management, eligibility determinations, and recertifications in strict compliance with HUD requirements. However, prior to the auditor’s testing that resulted in this finding, the GRHC had already begun discussing strategies to address these issues. Recognizing the need for stronger internal controls and process improvements, the GRHC initiated a plan to enhance file management, compliance monitoring, and process reviews. This plan includes: Process Mapping of Critical Functions to standardize workflows, ensure consistency, and eliminate inefficiencies. Digitization of forms to improve efficiency and reduce errors. Electronic document signing to streamline tenant file processing. Internal control checklists to ensure completeness and accuracy before file submission. Quality control (QC) review of all files by a manager before final submission to ensure compliance with HUD regulations. Strategies for these improvements began in August 2024 and are scheduled for full implementation by July 2025. GRHC leadership has been actively monitoring these efforts and meeting regularly to ensure progress toward compliance. Corrective Actions & Implementation Plan Corrective Action Responsible Group Completion Date Status Process mapping of critical workflows to ensure standardized procedures for eligibility and recertifications. Policy and Program Feb 2025 Completed Implement digitization of forms to streamline eligibility and recertification processes. Policy and Program 30-Apr-25 In Progress Introduce electronic document signing to enhance efficiency and reduce processing time. Policy and Program /IT 30-Apr-25 In Progress Develop and enforce internal control checklists for eligibility and recertifications. Policy and Program/IT 31-May In Progress Provide staff training on new processes and HUD compliance requirements. Policy and Program 30-Apr-25 Planned Conduct internal audits to evaluate the effectiveness of the new controls before manager QC begins. Policy and Program 30-Jun-25 Planned Require manager-level QC review of all tenant files before submission. Program Managers 01-Jul-25 Planned Implement a formal backup plan to ensure timely eligibility processing during staff absences or workload surges. ED/Program Directors 01-July-25 Planned Regular reporting to GRHC leadership on the status of tenant file compliance improvements. ED/Policy and Program Ongoing Planned Expected Outcome Full compliance with HUD requirements for eligibility and recertifications. Improved internal controls to prevent future deficiencies. A sustainable QC system for ongoing compliance monitoring. Monitoring & Follow-Up The Policy and Program Implementation Manager will oversee corrective actions and provide bi-weekly progress updates. The Executive Director will present the Corrective Action Plan at the next board meeting. Contact Person: Jose L. Capeles Title: Policy and Program Planning and Implementation Manager Date: 03/28/2025

Categories

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

Other Findings in this Audit

  • 1117045 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $37.56M
14.879 Mainstream Vouchers $2.14M
14.871 Section 8 Housing Choice Vouchers $634,363
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $532,061
14.877 Public Housing Family Self-Sufficiency Under Resident Opportunity and Supportive Services $432,160
14.235 Supportive Housing Program $154,754
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $115,318