Finding 569128 (2024-004)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-06-30

AI Summary

  • Core Issue: The Authority failed to conduct timely follow-up inspections for housing quality standards (HQS), risking tenant safety.
  • Impacted Requirements: Noncompliance with 24 CFR 982.404(a)(3) and (b)(2) regarding timely corrections of defects in housing units.
  • Recommended Follow-Up: Strengthen internal controls and procedures for HQS enforcement to ensure timely follow-ups on failed inspections.

Finding Text

Finding Reference: 2024-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions - HQS Enforcement Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Criteria Pursuant to 24 CFR 982.404(a)(3), the Authority must not make any housing assistance payments (HAP) for a dwelling unit that fails to meet the housing quality standard (HQS), unless the owner corrects the defect within the period specified by the Authority and the Authority verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). Furthermore, 24 CFR 982.404(b)(2) states that if an HQS breach caused by the family is life threatening, the family must correct the defect within no more than 24 hours. For other family-caused defects, the family must correct the defect within no more than 30 calendar days (or any PHA-approved extension). Condition Of the total of 5,989 tenants with failed inspections during the fiscal year, we identified eight cases in a statistically valid sample of 60 failed inspections in which the Authority did not perform follow-up inspections within the required timeframe and was not able to provide evidence showing that a PHA approved extension was granted. Cause of Condition The Authority did not have adequate controls in place to ensure that the HQS are being enforced or completed in a timely manner. Effect The Authority is not in compliance with the HQS enforcement requirements, which may result in tenants living in unsafe housing units. In addition, the Authority may be paying HAPs to property owners whose units have inadequate housing quality or may be incorrectly withholding HAPs to landlords who have properly corrected deficiencies within the required timeframes. Questioned Costs The Authority was able to provide documentation showing that the units were inspected after the required time frames and ultimately passed inspection. Therefore, questioned costs were not identified in connection with the units examined. Identification of Repeat Finding This is a repeat of finding 2023-003 reported for the year ended September 30, 2024. Recommendation The Authority should continue to develop procedures and strengthen its internal controls related to HQS enforcement to ensure that follow ups on failed inspections are performed timely. View of Responsible Officials and Planned Corrective Action See separately prepared Corrective Action Plan.

Corrective Action Plan

Reference Number: 2024-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions – HQS Enforcement 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 Housing Quality Standards (HQS) inspections and enforcement since transitioning the programmatic functions of the Housing Choice Voucher (HCV) program to third-party contractors. While significant strides have been made, the Authority acknowledges that further progress is necessary and remains actively engaged with its third-party HCV contractors to ensure that all HCV-assisted units meet and consistently maintain HUD’s HQS requirements. The Authority remains committed to ensuring that all units under contract are not only compliant but provide safe, sanitary, and decent housing in accordance with HQS regulations and the Authority’s Administrative Plan. The discrepancies noted in the audit were primarily due to inconsistencies in the application of enforcement timelines and insufficient documentation related to landlord extension requests and their corresponding approvals. Importantly, all delayed follow-up inspections identified during the audit were successfully completed outside the required timeframes. Each unit passed inspection and was found to be compliant with HUD HQS standards. Housing assistance payments (HAP) were accurately processed for these units, and no abatements were necessary. The Authority continues to refine its inspection protocols, improve documentation practices, and reinforce contractor accountability to ensure timely and compliant HQS inspections across the entire HCV portfolio. The Authority uses the Emphasys Elite software to schedule, record, and enforce HQS inspections. The Authority also uses its Customer Relations Management (CRM) system to track units that have failed an HQS inspection. To prevent recurrence, the Authority has already implemented the following corrective steps: • Daily review process of units that have failed and/or no-showed two or more consecutive inspections. The inspection department uses this process to accurately review the letter generation and notification process for HQS deficiencies and notices of abatement. The inspection department manually reviews and generates both letters to their respective parties (landlord/owner and tenant). • In addition to the daily morning review, at the close of business the HCV contractor will review the failed emergency inspections and will schedule any emergency re-inspections to ensure compliance with HQS enforcement rules and regulations. The Authority’s corrective steps outlined above will significantly strengthen its compliance efforts, reduce risk, and enhance the overall quality and integrity of the HCV program. 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

Categories

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 569122 2024-002
    Material Weakness
  • 569123 2024-002
    Material Weakness
  • 569124 2024-002
    Material Weakness
  • 569125 2024-003
    Significant Deficiency Repeat
  • 569126 2024-003
    Significant Deficiency Repeat
  • 569127 2024-003
    Significant Deficiency Repeat
  • 569129 2024-004
    Significant Deficiency Repeat
  • 1145564 2024-002
    Material Weakness
  • 1145565 2024-002
    Material Weakness
  • 1145566 2024-002
    Material Weakness
  • 1145567 2024-003
    Significant Deficiency Repeat
  • 1145568 2024-003
    Significant Deficiency Repeat
  • 1145569 2024-003
    Significant Deficiency Repeat
  • 1145570 2024-004
    Significant Deficiency Repeat
  • 1145571 2024-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $33.97M
14.850 Public and Indian Housing $8.65M
14.879 Mainstream Vouchers $6.74M
14.872 Public Housing Capital Fund $3.00M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $795,148