Finding 6714 (2023-002)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2023-12-28

AI Summary

  • Core Issue: The Housing Authority has significant control deficiencies in managing the waiting list for the Housing Choice Voucher Program, leading to noncompliance with federal and local guidelines.
  • Impacted Requirements: The Authority is not following its Admin Plan or the Code of Federal Regulations, particularly in record keeping, purging the waiting list, and maintaining selection order.
  • Recommended Follow-Up: The Agency should strictly adhere to its Admin Plan and federal regulations, and ensure proper documentation of applicants before transitioning to new management software.

Finding Text

Finding 2023-002 – Housing Choice Voucher Program– Subsidy ALN 14.871 – Internal Control over Waiting List – Eligibility – Noncompliance and Material Weakness Condition & Cause: We selected thirteen (13) tenants admitted during the fiscal year and ten (10) tenants admitted in June 2023, subsequent to year end. The selection was to determine whether or not the Housing Authority was in compliance with the Federal and local guidelines. Our review of the Section 8 waiting list unveiled control deficiencies in the management of the waiting list regarding record keeping, purging, and selection order. We were unable to gain assurance that the waiting list is maintained in accordance with the Admin Plan and the Code of Federal Regulations. In our review of one move-in during the fiscal year, we inquired about the status of fifty-one (51) applicants who were above the new admission in order. We noted that documentation was not readily available for seven (7) of these applicants. The Authority is not maintaining a clear audit trail as required by 24 CFR 982 Subpart E. We noted that the Authority does not purge the waitlist. The Authority sent update letters to lower ranked applicants for the purpose of updating contact and preference information only. Applicants are not removed from the waitlist if they do not respond to the update letter. The Authority is not following its Admin Plan, which states the PHA “will update and purge its waiting list at least annually to ensure that the pool of applicants reasonably represents interested families.” In our review of June 2023 admissions, we inquired about sixty-seven (67) applicants who were selected off the waitlist and found that thirteen (13) were selected out of order, or nineteen percent. Interest letters used to notify the applicant of selection for assistance are grouped into batches. Of the thirteen (13) applicants identified as selected out of order, seven (7) were mailed notice of selection before other applicants in their batch, and six (6) were mailed notice of selection after other applicants in their batch. Staff was unable to provide justification for the discrepancies. We noted that the Authority experienced difficulty in hiring, training, and retaining quality employees and are working with a high number of staff vacancies. This contributed to the instances of noncompliance uncovered during the review. Additionally, the Authority has contracted with a new software vendor and is in the process of cleaning data for transfer. We anticipate that the new software will ease the administrative burden that the current admissions process creates. Criteria: The Code of Federal Regulations and the Housing Authority’s Admin Plan Effect: Failure to maintain compliance can result in loss of funding for grants and other programs which require operations to have no audit findings and noncompliance. Recommendation: We recommend that the Agency more closely adhere to the Admin Plan and Code of Federal Regulations regarding management of the waitlist. Additionally, the Authority should true up the documentation of the applicants on the waiting list before transitioning to the new management software. 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 2023-002 – Housing Choice Voucher Program – Internal Control over Waiting List – Noncompliance and Material Weakness - Housing Choice Voucher Program - subsidy ALN #14.871 Corrective Action Plan: Finding 2023-002 correctly identifies the same underlying cause (recruiting and retaining qualified staff) as well as alluding to another underlying problem—antiquated software and IT systems—as contributing factors. Our detailed analysis of the issues giving rise to Finding 2023-001 and the strategic and comprehensive remedies being pursued will result in better outcomes in implementing RHA’s waiting list policies and procedures. For example, a new eligibility unit under an eligibility manager, will bring focus to sound waiting list management. However, another critical underlying cause is the system of waiting list preferences and having a waiting list that remains open regardless of the size. RHA proposes to do away with all preferences except that of giving higher priority to residents of Wake County and those who are employed in Wake County. An applicant’s preference can change multiple times while they are on the waiting list. Anytime one applicant provides new information that changes their preferences and position on the waiting list, the waiting list changes. Greatly simplifying RHA’s waiting list by eliminating most preferences will result in a more manageable waiting list going forward. An additional remedy RHA has implemented is closing the HCV waiting list for the first time in its history. This will greatly reduce the administrative burden of adding new applicants on a continual basis and then annually updating (purging) an unnecessarily large waiting list. Staff in the eligibility unit will have more time to focus on better management of the waiting list. These additional changes in RHA’s program management will complement the other changes discussed under Funding 2023-001. Person Responsible: HCV Director Priscilla Batts and her Eligibility Manager Anticipated Completion Date: The system of closing and opening waiting lists based on the adequacy of the size of the waiting list has been implemented on October 1, 2023. It is anticipated that the list will reopen on April 1, 2024, RHA’s go-live date for the new software. The elimination of most preferences will be implemented at the same time—April 1, 2024.

Categories

HUD Housing Programs Eligibility Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 6712 2023-003
    Significant Deficiency
  • 6713 2023-001
    Material Weakness Repeat
  • 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