2024-003 Housing Choice Voucher Tenant Files: Eligibility
Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871)
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
This is a repeat finding of 2023-002 from September 30, 2023 (Originally reported as Material non-compliance and Material Weakness in Internal Control over Compliance under finding 2019-001 from September 30, 2019)
Statement of Condition: Out of a total tenant population of approximately 1,118 vouchers, 25 files were selected for testing, and the following errors were discovered.
• 2 tenant files had the following error:
o The HAP contract in the tenants’ file was not signed by a representative of Ocala Housing Authority.
• 1 tenant file had the following error:
o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will decrease the Housing Assistance Payment by $4.
• 1 tenant file had the following error:
o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $23.
• 1 tenant file had the following error:
o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $7.
• 1 tenant file had the following error:
o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates for a 1-bedroom unit. The 2024 utility allowance rates for a 2-bedroom unit should have been used. Correcting this error will increase the Housing Assistance Payment by $20.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants.
The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being sent to the Compliance Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the Counselor handling specialty vouchers, will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam during the next 24 months, as budget permits.