Finding 565660 (2024-002)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-06-20

AI Summary

  • Core Issue: There are significant errors in tenant file management, including delays in processing and missing documentation.
  • Impacted Requirements: Noncompliance with federal regulations and agency guidelines can lead to financial misstatements and potential funding losses.
  • Recommended Follow-up: Conduct a comprehensive audit of tenant files and enhance monitoring and training for occupancy specialists to ensure compliance.

Finding Text

Finding 2024-002 – Continuum of Care Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Continuum of Care Program - subsidy ALN #14.267 Condition & Cause: We selected a sample of five (5) files for review. We noted the following errors of noncompliance: • Two (2) files which contained delays in processing End of Participations (EoP) • Three (3) files which did not contain evidence of an EIV in the file. Of these files two (2) also contained untimely reexaminations which in turn caused the rent register to match actions effective in calendar year 2022. Lastly of these files one (1) contained an income miscalculation Criteria: The Code of Federal Regulations 24 part 578, the Housing Authority’s Admin Plan, and specific HUD guidelines in documenting and maintaining the Continuum of Care tenant files. Effect: Failure to conduct timely recertifications and to properly calculate HAP can result in a misstatement of HAP expense leading to improper funding for the CoC program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding. Recommendation: We recommend that the Agency conduct a thorough tenant file audit of existing tenants in the Continuum of Care program. We also recommend that the Agency increase their monitoring and review of the Continuum of Care program 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

Finding 2024-002 – Continuum of Care Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fiscal year-end September 30, 2025: a. Program Coordinators will maintain all Continuum of Care Tenant files in individual file folders designated by special purpose voucher programs. All loose documents will be anchored in tenant files. b. An action plan has been developed for the Continuum of Care programs to ensure that all program files are HUD, State, and HACG compliant starting with October 1, 2024, files through the current. c. Continuum of Care fiscal year 2024 (October 2023-September 2024) re- exams and interims will be caught up and completed as they become effective. All tenant files will be reviewed and compliant by FYE2024. d. All late/overdue re-exams will be compliant by FYE2024. e. During FYE2024, the Housing Choice Voucher Director will perform quality controls on all Continuum of Care tenant files processed each month prior to initialization (25th-30th of each month). f. File checklist sheets will be placed in each file upon quality control review to be signed off by the Housing Choice Voucher Director. g. Additional training will be required and ongoing for Program Coordinators. h. Other internal control measures will be implemented as deemed necessary by the Deputy Executive Director/COO, to eliminate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2025

Categories

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

Other Findings in this Audit

  • 565659 2024-001
    Significant Deficiency Repeat
  • 1142101 2024-001
    Significant Deficiency Repeat
  • 1142102 2024-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 Public Housing Operating Fund $4.12M
14.872 Public Housing Capital Fund $2.13M
14.267 Continuum of Care Program $481,371
14.241 Housing Opportunities for Persons with Aids $372,827
14.871 Section 8 Housing Choice Vouchers $336,641
14.182 Lower Income Housing Assistance Program_section 8 New Construction/substantial Rehabilitation $315,678
14.879 Mainstream Vouchers $199,270
14.896 Family Self-Sufficiency Program $133,583
14.169 Housing Counseling Assistance Program $7,790
97.024 Emergency Food and Shelter National Board Program $4,695