Finding Text
Public Housing Program – CFDA No. 14.850a, Section 8 Housing Choice Voucher Program; Grant period – fiscal year ended March 31, 2023 Criteria The Code of Federal Regulations (CFR’s) and HUD PIH Notices and Handbooks provide requirements and guidance for which the Public Housing and Section 8 Housing Choice Voucher Programs are to be administered and operated under. Condition and Perspective During July of 2023, HUD conducted a Remote PIH Compliance Monitoring review of the Authority’s Public Housing and Section 8 Housing Choice Voucher Programs. The Review Report dated October 5, 2023, included the following Review Findings: Review Finding 1 – The HAS is not compliant with HUD’s requirement that at least one commissioner be a resident of the agency’s Public Housing Program. Review Finding 2 – Certain written policies and procedures lacked board approval. Review Finding 3 – (Unaudited) fiscal year ended March 31, 2022 financial statements were not presented to the board. Review Finding 4 – A review of the petty cash reconciliation completed for the month of March 2023 showed the custodian also completed the reconciliation. Review Finding 5 – Expenses totaling $40.46 were identified as unallowable program costs and will require reimbursement to the HAS’s local PH account from a non-federal source. The unallowable expenses were for drinks purchased at Home Depot for HAS maintenance employees and charged to AMP 6. Review Finding 6 – The petty cash reconciliation for the month of March 2023 contained receipts and invoices for a party that the HAS hosted for residents utilizing Tenant Participation (TP) Funds of $1,220.97. Review Finding 7 – The HAS is not adhering to their Public Housing (PH) lease agreement terms or Admissions and Continued Occupancy Policy (ACOP). Both documents state that tenant rental payments are due on the seventh day of each month and establish that a failure to pay will result in a Notice of Termination (NOT) being issued to the tenant and the filing of a Dispossessory Warrant. A review of the HAS Tenants Account Receivable report dated July 18, 2023, showed 28 tenants between Frazier Homes and Yamacraw Village with outstanding balances ranging from $1,048 - $10,652. Further review revealed seven instances in which the NOT was issued to tenants after 4 – 10 months of non-payment, which exceeded the seven-day window outlined in the HAS policies. Review Finding 8 – The Field Office accessed a Debts Owed to PHAs & Terminations Report in the Enterprise Income Verification (EIV) system on August 3, 2023. The report showed debts owed by former PH program participants have never been reported in EIV by the HAS. Debts owed by former Section 8 program participants have only been reported by the HAS for six tenants, with the most recent End of Participation (EOP) date of November 30, 2018, or 1,707 days earlier than the report. The HAS should have reported any debts owed by former program participants into the Debts Owed Module within 60 calendar days from the effective date of an EOP action recorded on line 2b of the form HUD-50058, in accordance with PIH Notice 2011-65. Review Finding 9 – The PHA does not have a separate Section 3 policy. Cause Failure to execute certain controls over requirements of the Programs. Effect Noncompliance with certain requirements of the Programs. Questioned Costs - $1,261.43 Recommendation The Authority has responded to HUD’s Review Findings with specific corrective actions it has implemented and is in the process of implementing. We recommend that the Authority continue implementing the remainder of its corrective actions within the time frame outlined in its response communicated to HUD. Reply Management has implemented, and is in the process of implementing, specific corrective actions to address each of HUD’s Findings. The Authority’s Deputy Director, Kenneth Clark has assumed the responsibility of implementing the specific corrective actions and anticipates complete implementation by January 31, 2024.