Reference Number: 2024-003
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Choice Cluster
Federal Catalog Number: 14.871 and 14.879
Federal Grant Number: Not Applicable
Category of Finding: Special Tests and Provisions (Housing Quality
Standards Inspections)
Classification of Finding: Significant Deficiency in Internal Control over Compliance
Instance of Noncompliance
Authority’s Response & Actions Taken
The Authority has made considerable progress in addressing the backlog of annual inspections that resulted from restricted unit access and the temporary implementation of HUD waivers during the COVID-19 national pandemic. These necessary public health measures, while appropriate at the time, contributed to delays in fulfilling Housing Quality Standards (HQS) inspection requirements. The Authority acknowledges that additional progress is still needed and remains actively engaged with its third-party Housing Choice Voucher (HCV) contractors to ensure timely completion of all outstanding inspections. The Authority is fully committed to ensuring that all units under contract meet and exceed HUD’s standards for safe, decent, and sanitary housing, in accordance with HQS and the Authority’s Administrative Plan. All five annual inspections with exceptions noted during the audit were inspected after the required timeframes and ultimately passed inspection with the units determined to be in full compliance with HUD requirements. The Authority uses the Emphasys Elite software to check against HUD's PIH Information Center (PIC) system to identify units with outstanding Housing Quality Standards (HQS) Inspections. The Authority has scheduled HQS Inspections for the units identified to be out of compliance. Key strategies and controls in place are as follows:
Project-Based Program:
For the PBV program, the Authority has already implemented the following procedures to result in timely HQS inspections of all units.
1. Matching data between the Emphasys Elite system of records to ensure the most overdue inspections are scheduled.
2. A bulk inspection process was implemented effective November 1, 2024. Through this process, all units for a particular PBV site are scheduled for their annual inspections in the same month each year. This ensures that all units are inspected annually. The scheduling process includes:
a. Posting the bulk inspection schedule on the website. This is an annual schedule which identifies properties, property management, and the month the project will be inspected.
b. Providing notice to the applicable site owner/manager of the inspection date and the units to be inspected. The notice will include information on how to prepare for the inspection, a request to have site staff accompany the inspector, and a reminder to notify residents so access can be gained even if no one is home.
c. Sending individual inspection notices to the owner and participant for each scheduled inspection. For the PBV portfolio, staff will work directly with property management and developers to ensure access to units is continuously granted. Upcoming bulk inspections are also discussed on calls with owners. This allows for increased planning and respect for noticing timelines.
Tenant-Based Program:
• Review the report of outstanding HQS Inspections on a weekly basis.
• Schedule outstanding HQS Inspections in order of aging date.
• Conduct HQS Inspections prior to the anniversary date of previously completed inspection.
• Running a monthly report of failed inspections and comparing them with future scheduled inspections to ensure that a second inspection has been scheduled.
• Running a monthly report to identify units with two failed inspections to ensure all have been abated correctly.
• Implement weekly monitoring to ensure all units are properly abated and lifted timely when units pass inspections and contracts are properly terminated after being in abatement for 180 days without a cure. The Authority has worked with Emphasys to identify the best ways to sort aged HQS inspections due and generate/schedule in bulk, as well as maximize the Inspector’s workday by routing the tenantbased units in a way that flows in a clear and orderly manner. Similar to the handling of delinquent annual reexaminations, the Authority is checking the data in PIC with the system of records and processing 50058 corrections where inspections have been completed but rejected in PIC due to out of sequence effective dates and any other fatal errors that require corrective action. The procedures for the project-based and tenant-based programs are already in effect, and the backlog of inspections has been substantially reduced as illustrated by a reporting rate of 99% for SEMAP Indicator 12 annual HQS inspections as of May 31, 2025. Monthly performance reports are
also reviewed by management to ensure inspection timeliness is maintained.
Anticipated Implementation Date
September 30, 2025
Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action
HCV Contractors
Kendra Crawford, Director of Housing Operations