Finding 6712 (2023-003)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2023-12-28

AI Summary

  • Core Issue: Seven tenant files were recertified late, violating annual review requirements.
  • Impacted Requirements: Noncompliance with 24 CFR 960.257(a)(1) and internal policies on tenant file management.
  • Recommended Follow-Up: Identify and complete overdue recertifications; enforce compliance with policies and regulations.

Finding Text

Finding 2023-003 – Low-Income Public Housing – ALN 14.850 – Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Condition & Cause: Our review of seventy (70) Low Income Public Housing tenant files revealed that there was a total of seven (7) annual recertifications completed past due, which represent 10% of the total files examined. Per 24 CFR 960.257(a)(1), “the PHA must conduct a reexamination of family income and composition at least annually.” These reexaminations not completed annually are reported as an audit finding for noncompliance and a significant deficiency. Criteria: The Code of Federal Regulations, the Housing Authority’s Admissions and Continued Occupancy Policy, and specific HUD guidelines in documenting and maintaining the Low-Income Public Housing tenant files. Recommendation: We recommend that the Agency determine the number of outstanding annual reexaminations that are past due in the Low-Income Public Housing program and complete them. We also recommend that the Agency enforce their ACOP and Federal Regulations regarding systematically performing reconciliations. Effect: Failure to maintain compliance can result in loss of funding for grants and other programs which require no noncompliance. Noncompliance can also lead to a misstatement of program revenue, and the corresponding appropriation needs of the Agency. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

Finding 2023-003 – Low-Income Public Housing Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Corrective Action Plan: The underlying causes of Finding 2023-03 include many, if not all, the causes underlying Finding 2023-01: 1. Pandemic effects on staffing and resident habits. 2. Underinvestment in staff compensation. 3. Underinvestment in training. 4. Underinvestment in adequate staffing levels. 5. An organizational structure that diffuses accountability for compliance, including timeliness of annual recertifications. In the Housing Management Department, all rent calculations are centralized and completed by one Central Office employee. A management system that does not hold property managers accountable for compliance and relies on one employee doing rent calculations for over 1,200 residents is likely to result in lack of compliance when other negative factors (1 to 5) come into play. RHA’s action plan includes: • Competitive compensation to attract and retain qualified staff. • Increasing senior management staff so that portfolio managers will have manageable supervisory loads of no more than five property manager each. • Reorganizing property staffing by upgrading office assistants to Housing Management Specialists, who will perform all recertication tasks, reviewed by their managers. • All Housing Management Specialists will receive certification training on rent calculation as well as property manager certification for high-performing staff who will become eligible for promotion. • Sites with complex social and other problems will have dedicated property managers, instead of splitting managers between sites. • New state-of-the-art software will greatly improve efficiency in communications with residents, paperless processes, and allow managers and their staff to gauge their performance, including timeliness on an ongoing basis. More qualified and talented property managers, supervised, mentored, and held accountable by portfolio managers, as well as supported by trained and higher qualified housing management specialists will work as a team to ensure compliance, including timely completion of recertications. Person Responsible: Sonia Anderson Director of Housing Management, portfolio managers, and property managers. Anticipated Completion Date: Implementation of all remedies will be completed by June 30, 2024.

Categories

HUD Housing Programs Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 6713 2023-001
    Material Weakness Repeat
  • 6714 2023-002
    Material Weakness
  • 583154 2023-003
    Significant Deficiency
  • 583155 2023-001
    Material Weakness Repeat
  • 583156 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.850 Public and Indian Housing $5.25M
14.872 Public Housing Capital Fund $4.49M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $363,375
14.871 Section 8 Housing Choice Vouchers $118,314