Finding 569828 (2024-003)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-06-30

AI Summary

  • Core Issue: 42 tenant files reviewed showed multiple deficiencies, including missing documents and incorrect income calculations.
  • Impacted Requirements: Non-compliance with 24 CFR 983.353 due to inadequate internal controls for tenant file management.
  • Recommended Follow-Up: Revise procedures, enhance staff training, and address deficiencies to ensure compliance with HUD requirements.

Finding Text

Condition: Out of an approximate population of 450 of tenants, a total of 42 files were selected for testing and the following deficiencies were noted: • Nine files were missing the 214 declaration documents performed for the FYE 2024 annual recertification, • Seven files were missing EIV report for the FYE 2024 annual recertification, • Five files were missing supporting documentation for income reported, • Two files were missing 9886 release of information documents during the FYE 2024 annual recertification process, • Two files had incorrect calculation of income allowances, and • One file was missing information to determine custody of minor child. Criteria: 24 CFR 983.353 requires 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 42 tenant files out of the population, 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 Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges and did not have the available staff to follow the established internal controls to ensure proper compliance with regards to timely recertifications and collection of required HUD documentation to verify eligibility and calculate accurate housing assistance payments. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: Unknown. Auditor Recommendations: The Authority should evaluate and change their established procedures and controls in place to ensure full compliance in regards to eligibility of recertifications and should provide staff training on these procedures. The Authority needs to correct the deficiencies noted in the internal quality control sample and consider the impact to the rest of the population of tenant files that were not selected as part of the sample. Management Response: See Corrective Action Plan.

Corrective Action Plan

The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Contract (ACC), the program receives over $90M from the United States Department of Housing and Urban Development (HUD) and assist over 7,700 families each year. The ACC requires JHA to comply with federal regulations and HUD guidelines, as amended from time to time. Audit Findings Berman Hopkins Wright & LaHam, CPAs and Associates, LLP conducted the recent FY2024 JHA Audit (Period: October 1, 2023 – September 30, 2024) and identified continued material weakness findings within the JHA Housing Choice Voucher (HCV) program including but not limited to: Material Weaknesses in Internal Controls, Material Weaknesses in Non-Compliance and Material Weaknesses in the Housing Quality Standards (HQS) Inspection process. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP previously conducted JHA’s FY2023 audit (Period: October 1, 2022 – September 30, 2023) and FY2022 audit (Period: October 1, 2021 – September 30, 2022) which disclosed consecutive historical material weaknesses in JHAs internal controls and noncompliance of the Housing Choice Voucher (HCV) program. Under new CEO leadership at JHA, a request to the JHA Board of Commissioners is in place for a vote on Friday, June 27, 2025, to authorize the following action of Nan McKay & Associates to Administer, Manage and Operate the JHA Housing Choice Voucher Program for an effective date of Monday July 7, 2025. Pending Resolution: AUTHORIZE THE AWARD OF THE MIAMI-DADE HOUSING & COMMUNITY DEVELOPMENT PIGGYBACK CONTRACT IN THE NOT-TO-EXCEED AMOUNT OF 72% OF THE ADMINISTRATIVE FEES CONCURRENT WITH THE EXISTING CONTRACT TERMS TO NAM MCKAY AND ASSOCIATES, FOR HOUSING CHOICE VOUCHER MANAGEMENT AND OPERATIONS. As evidenced by the increase in overall HCV audit findings, loss of federal revenues, inability to correctly serve existing and future HCV program participants, noncompliance on both a local and federal level for section 8 program funding for the administration and operations of the HCV program, immediate action is requested to authorize Nan McKay & Associates to administer and operate JHA’s HCV program immediately. Combined with a plethora of likely compliance issues and deteriorated financial condition, these concerns pose a significant threat to both the immediate and long-term success of Jacksonville’s HCV program. Responsible: Nan McKay & Associates POINT OF CONTACT: Steven Rosario, Sr. Director EMAIL: srosario@nanmckay.com JHA POC: Roslyn Phillips, Interim COO EMAIL: RPHILLIPS@JAXHA.ORG

Categories

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $92.09M
14.850 Public and Indian Housing $11.59M
14.872 Public Housing Capital Fund $5.90M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $2.92M
14.871 Section 8 Housing Vouchers $1.94M
14.879 Mainstream Vouchers $1.05M
14.895 Jobs-Plus Pilot Initiative $839,921
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $683,915
14.896 Family Self-Sufficiency Program $369,946
14.870 Resident Opportunity and Supportive Services- Service Coordinators $153,665
14.218 Community Development Block Grants/entitlement Grants $70,000