Finding 703 (2021-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2021
Accepted
2023-10-25

AI Summary

  • Core Issue: The Authority failed to maintain complete tenant files, leading to material non-compliance with eligibility requirements for the Section 8 Housing Choice Vouchers Program.
  • Impacted Requirements: Missing documents include original applications, lead-based paint forms, signed leases, rent reasonableness assessments, and annual inspection reports, affecting compliance with federal regulations.
  • Recommended Follow-Up: Implement stronger internal control procedures to ensure all required documents are maintained and accessible, and issue directives to staff regarding proper file management and archiving practices.

Finding Text

Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 3,383 units. Of a sample size of forty (40) tenant files, the following was noted: Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 3,383 units. Of a sample size of forty (40) tenant files, the following was noted:  Original application was missing in 3 files  Lead based paint form was missing in 5 files  Signed lease was missing in 5 files  Rent reasonableness was missing in 10 files  Annual inspection report was missing in 15 files. Our sample size is statistically valid. Known Questioned Costs: $294,952. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward.

Corrective Action Plan

Finding 2021-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Material Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 3,383 units. Of a sample size of forty (40) tenant files, the following was noted: Original application was missing in 3 files, Lead based paint form was missing in 5 files, signed lease was missing in 5 files, Rent reasonableness was missing in 10 files , Annual inspection report was missing in 15 files. Our sample size is statistically valid. Known Questioned Costs: $294,952. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward. Zulieka Boykin, Executive Director, will be responsible to implement this corrective action by June 30, 2022.

Categories

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

Other Findings in this Audit

  • 577145 2021-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $45.77M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $1.16M
14.235 Supportive Housing Program $416,260
14.879 Mainstream Vouchers $404,166
14.896 Family Self-Sufficiency Program $93,953