Finding Text
Finding No. 2022 - 002: Federal Agency: Department of Housing and Urban Development ("HUD") Federal Program Title: Moving to Work Demonstration Program (HCVP Only) Federal Assistance Listing Number: 14.881 Award Period: January 1, 2022 through December 31, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition/Context A sample of 60 tenant files tested found that 15 files did not have HUD-50058 data uploaded to the PIH Information Center ("PIC") in a timely manner. Our sample was a statistically valid sample. Questioned Costs N/A Criteria Tenant information must be uploaded to the PIC system for each HUD-50058 report completed no later than 60 calendar days from the effective date of any action recorded of the form HUD 50058. Cause BRHP's Administrative Plan allows for retroactive effective dates for interim changes that will benefit the family when income decreases, as opposed to selecting a future effective date and forcing the family to pay their portion when they do not have the income to support it. Typically, staff would submit 50058 actions to HUD using the PIC system at least once per month. Action effective dates must be for the first of any month. In 2022, after the prior audit finding, BRHP began weekly submissions of 50058 actions to PIC. Fourteen of the fifteen PIC submissions cited above as not submitted timely occurred prior to the issuing of last year's finding. The PIC submission occurring after the issuing of the prior audit finding was a retroactive interim recertification with a reduction in income. That action was approved 59 days after the effective date, causing it to be late for submission to PIC. Effect The delay in uploading information to the PIC system may result in inaccurate reporting to HUD which is used for funding purposes. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit, Finding No. 2021-001. Recommendations We recommend BRHP perform their reporting to HUD on a weekly basis rather than on a monthly basis. Views of the Responsible Officials At this time, all files selected for the audit have corresponding records successfully submitted to HUD through the PIC submission portal. BRHP will continue weekly PIC submissions and clearing of fatal errors and now have two staff trained on PIC submissions as a redundancy measure. It is not unusual for BRHP to process retroactive actions and at times, the effective date of the action can be for a date several weeks in the past. If PIC submissions are completed weekly rather than monthly, there will be more opportunities to upload the 50058 in accordance with the 60-day required period. BRHP explored the possibility of submitting a Moving To Work activity specifically to allow for PIC submissions of retroactive actions past the 60-day window, however, ultimately decided it was not an activity that would fall within the regulatory framework for the Moving To Work program. As a result, BRHP will limit retroactive actions to no more than 45-days prior to effective date, ensuring ample time for submission prior to the 60-day window lapsing.