Finding Text
Finding Number: 2024‐002
Repeat Finding: Yes, 2023‐101
Program Name/Assistance Listing Title: Housing Voucher Cluster
Assistance Listing Number: 14.871
Federal Agency: Department of Housing and Urban Development
Federal Award Number: N/A
Pass‐Through Agency: N/A
Questioned Costs: N/A
Type of Finding: Noncompliance, Material Weakness
Compliance Requirement: Special Tests and Provisions
Criteria
Public Housing Authorities (PHAs) participating in the Housing Choice Vouchers program must do the
following in relation to special tests and provisions:
PHAs are required to enter into general depository agreements (GDA) with their financial
institutions in the form required by Housing and Urban Development (HUD). (24 CFR section
982.156)
PHAs are required to maintain complete and accurate accounts including the balances of HAP
and administrative fee equity. (24 CFR section 982.158)
PHAs are required to inspect units leased to determine if they meet Housing Quality Standards
(HQS). If a unit fails an inspection, it must be repaired within 30 days if not a life‐threatening
condition. (24 CFR section 982.405) If the owner does not correct the cited HQS deficiencies
within the specified correction period, the PHA must stop (abate) HAPs beginning no later than
the first of the month following the specified correction period or must terminate the HAP
contract (24 CFR section 982.404).
PHAs must have written policies in its HCVP administrative plan for selecting applicants from
the waiting list and PHA documentation must show that the PHA follows these policies when
selecting applicants for admission from the waiting list. (24 CFR sections 982.204 and 982.205).
Condition
Internal controls were not functioning to maintain adequate documentation.
Cause
Internal controls and review procedures did not function as designed throughout the year for all
required compliance requirements.
Effect
The PHA was not in compliance with special tests and provisions requirements. Context
We noted the following items during our review of special tests and provisions requirements for the
Housing Voucher Cluster:
An executed copy of the depositor agreement as required by HUD was not maintained.
Prior year ending equity balances reported as part of the HUD REAC submission did not agree
to beginning equity balances.
For one of 15 continuing tenants reviewed, the City did not maintain documentation following
up on a failed HQS inspection.
For one of 20 waiting list applicants reviewed, the date applied did not agree with the
application received date by one day. The applications position on the waitlist was affected by
two spots.
Emergency Housing Voucher (EHV) program applicants were added to the regular Housing
Choice Voucher (HCV) waiting list. However, those selected for EHV were not limited by those
on the regular HCV waiting list. EHV vouchers were still distributed on a first come basis to
those qualifying for the EHV program. However, the City should maintain a separate wait list
for the EHV program.
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The PHA should ensure it maintains documentation required by HUD. This includes an executed copy
of the depositor agreement, information supporting changes in equity balances, and documentation
supporting the follow up of failed HQS inspections. In addition, the PHA should ensure review
procedures over the follow up of failed HQS inspections and maintenance of the waiting list are
operating appropriately.
Views of Responsible Officials
See Corrective Action Plan.