Finding 59500 (2022-001)

Material Weakness Repeat Finding
Requirement
Eligibility
Questioned Costs
-
Year
2022
Accepted
2023-09-29

AI Summary

  • Core Issue: The Housing Authority of the City of Pittsburgh lacks effective internal controls, leading to missing tenant files and untimely recertifications.
  • Impacted Requirements: Compliance with HUD-50058 form submissions and maintenance of essential tenant documentation is not being met, risking eligibility determinations and accurate subsidy calculations.
  • Recommended Follow-Up: Implement stronger procedures for timely recertification and documentation retention, along with training to prevent future lapses due to staff turnover.

Finding Text

Finding 2022-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021 Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted 2 tenant files (which provide eligibility and reporting information) were unable to be provided. Additionally, we noted 4 tenants for which the most recent recertification was not completed on a timely basis. Also noted was one tenant file that did not contain the required income verification support. In all cases previously described, the HUD-50058, Family Report (OMB No. 2577-0083) (HUD-50058) forms prepared by the Authority were not completed and/or did not contain support for the calculations. All instances related to the MTW - Housing Choice Voucher program. In addition, we noted the following exceptions related to the tenant recertification process: We noted two instances where the application was missing or not signed, three instances where the tenant file was missing a social security card or driver?s license, two instances where the signed HUD Form 9886 was missing, two instances where a signed lease agreement was missing, and two instances where a signed HAP contract was missing. Criteria: The Authority is required to prepare and submit HUD-50058 form each time the Authority completes an admission, annual reexamination, portability move-in, or other change of unit for a family. The form provides HUD and the Authority with vital eligibility data for each program participant such as family composition, family income, the assets and liabilities of program participants, and ultimately provides for the calculation of tenant rent and rental/housing assistance payments for each program participant. In relation to the missing documents noted in the second paragraph above, these documents are to be maintained to support the eligibility of the tenant, and are also required to be maintained to provide support for the tenant income and eligibility determinations completed on the HUD-50058 form. The signed lease and HAP contracts are also required to ensure appropriate amounts are used in calculation subsidy payments, and appropriate payments are made to landlords for the housing provided. Cause: During the year, the Authority experienced turnover within several key positions, coupled with other logistical staffing challenges, that led to deficiencies in internal control processes over these areas. Effect: HUD-50058 forms provide essential information to HUD as well as being used by the Authority to determine program eligibility. In addition, the HUD-50058 form is used for the calculation of tenant rent and rental/housing assistance payments. Without this required documentation, this could lead to ineligible tenants being housed through the Authority program, and/or overpayments or underpayments of rental assistance, and incorrect information being reported to HUD. Questioned Costs: Unknown Recommendation: We recommend that the Authority implement additional procedures to ensure biennial recertification and the related HUD-50058 forms are prepared timely and accurately and that all supporting documentation is obtained and retained. In addition, appropriate training and planning should be performed to ensure that future turnover in the organization does not lead to a lapse in internal controls over compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.

Corrective Action Plan

Finding 2022-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021 Maher Duessel Finding Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted two (2) tenant files (which provide eligibility and reporting information) were unable to be provided. Additionally, we noted four (4) tenants for which the most recent recertification was not completed on a timely basis. Also noted was one (1) tenant file that did not contain the required income verification support. In all cases previously described the HUD-50058 Family Report (OMB No. 2577-0083) (HUD-50058) forms prepared by the HACP were not completed and/or did not contain support for the calculations. All instances related to the MTW ? Housing Choice Voucher (HCV) Program. In addition, we noted the following exceptions related to the tenant recertification process: We noted two (2) instances where the application was missing or not signed, three (3) instances where the tenant files was missing a social security card or driver's license, two (2) instances where a signed lease agreement was missing and two (2) instances where a signed HAP contract was missing. HACP Management Response/Action Taken: Action Taken: The HACP will continue to monitor and train staff regarding processes and procedures, to include and not limited to the HUD's hierarchy of income verification. In fiscal year (FY) 2022 the HCV Department had a significant turnover in line and managerial staff. The HACP promoted an aggressive hiring plan to attract new talent to fill vacant positions due to the great resignation that the HACP along with other national Agencies continue to experience. In addition, the HACP retained the services of CVR and Associates to train newly hired staff on all aspects of the HCV Program, to include and not limited to recertifications, contracts, interims, and rent increases. The HACP will continue managerial and internal audits by the HACP Internal Compliance Department to reduce the necessity of corrections subsequent to the initial submission. The HACP continues to: ? Send notices regarding re-certifications 120 days in advance of the due date, ? Require Managers to review reports to assure timely submission of re-certifications, ? Utilize the Internal Compliance (IC) Department to review and sample files from the Occupancy and the HCV portfolio, ? Make corrections when discovered, ? Make payment adjustments to participant accounts when errors are discovered and corrected. ? The HACP will offer periodic staff training on re-certification, ? The HACP offers participants the use of technology to complete paperwork. During FY 2022, the HACP was closed to the public. In July of 2023, the HACP opened a "One Stop Shop" that is open to the public from 8 a.m. to - 4:30 p.m. daily. The One Stop Shop has is staffed with four (4) full-time staff members to receive information from participants and landlords to provide timely customer service. The opening of the One Stop Shop has been successful in receiving the public and responding to concerns.

Categories

HUD Housing Programs Eligibility Reporting

Other Findings in this Audit

  • 59501 2022-002
    Material Weakness
  • 635942 2022-001
    Material Weakness Repeat
  • 635943 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $150.88M
14.871 Section 8 Housing Choice Vouchers $489,128
14.896 Family Self-Sufficiency Program $361,952
14.879 Mainstream Vouchers $206,054
14.218 Community Development Block Grants/entitlement Grants $204,254
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $196,088
14.870 Resident Opportunity and Supportive Services - Service Coordinators $44,170