Finding 962684 (2023-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-27
Audit: 298666
Organization: Lansing Housing Commission (MI)

AI Summary

  • Core Issue: The Commission failed to properly calculate tenant incomes and retain necessary documentation for eligibility, leading to significant deficiencies and repeat findings.
  • Impacted Requirements: Compliance with federal regulations regarding tenant rent adjustments and documentation retention (24 CFR Sections 960.253, 960.257, and 960.259) was not consistently met.
  • Recommended Follow-Up: Implement stronger controls and staff training for eligibility determinations, conduct a full audit of tenant files, and ensure proper documentation is maintained for compliance.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name 14.850, U.S. Department of Housing and Urban Development, Public and Indian Housing Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency and material noncompliance with laws and regulations Repeat Finding Yes 2022-001 Criteria As a condition of a tenant's admission or continued occupancy, the Commission is required to adjust the tenant rent and housing assistance payment as necessary using documentation from third party verification (24 CFR Sections 960.253, 960.257, and 960.259). Condition For 8 tenants in a sample of 23 tenants selected in conjunction with eligibility testing, the Commission failed to either correctly calculate family income composition or did not retain required documentation supporting eligibility determinations. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context During testing of 23 tenants selected for eligibility testing, we identified the following issues: For 2 of the 23 tenants selected, the Commission did not retain the appropriate consent from the tenant to verify third party income. For 1 of the 23 tenants selected, the Commission did not retain documentation of the tenant's ID/Social Security number to independently verify citizenship. For 6 of the 23 tenants selected, the Commission incorrectly calculated the tenants' annual income due to administrative errors leading to inputs in to the calculation not agreeing to the underlying third party income verification received. Cause and Effect Controls to ensure initial eligibility determinations and eligibility recertifications were performed in accordance with federal regulations were not consistently followed. This led to an inability by the Commission to identify all timeliness and retention issues, as well as family income composition calculation errors. Recommendation The Commission should ensure that it has the appropriate controls and personnel in place to perform all eligibility determinations and recertifications in accordance with federal regulations. Controls should include proper reviews of the recertification documentation to ensure that family income composition is properly calculated, and that appropriate documentation is retained in the tenant's file for third party verification consent and to support the eligibility determinations made. Views of Responsible Officials and Corrective Action Plan The Commission is implementing a plan to internally audit 100 percent of all tenant files in the Low Income Public Housing (LIPH) program. This plan involves both the use of experienced employees and an outside consultant. As part of the plan, a system for timely updating and automating files will be implemented, recurring compliance issues will be identified and addressed, and expanded formal training and specific training will take place from the consultant. An additional level of review will also be put in place to assist in catching any inconsistencies in the process. The Commission has also added an operations manager and a staff person to oversee the LIPH program. These additional staff will be incorporated into the overall plan to strengthen controls to ensure program compliance.

Categories

HUD Housing Programs Eligibility Significant Deficiency

Other Findings in this Audit

  • 386240 2023-002
    Significant Deficiency
  • 386241 2023-002
    Significant Deficiency
  • 386242 2023-001
    Significant Deficiency Repeat
  • 386243 2023-003
    Material Weakness
  • 386244 2023-004
    Material Weakness
  • 386245 2023-003
    Material Weakness
  • 386246 2023-004
    Material Weakness
  • 386247 2023-003
    Material Weakness
  • 386248 2023-004
    Material Weakness
  • 386249 2023-003
    Material Weakness
  • 386250 2023-004
    Material Weakness
  • 386251 2023-003
    Material Weakness
  • 386252 2023-004
    Material Weakness
  • 386253 2023-003
    Material Weakness
  • 386254 2023-004
    Material Weakness
  • 386255 2023-003
    Material Weakness
  • 386256 2023-004
    Material Weakness
  • 386257 2023-003
    Material Weakness
  • 386258 2023-004
    Material Weakness
  • 386259 2023-003
    Material Weakness
  • 386260 2023-004
    Material Weakness
  • 386261 2023-003
    Material Weakness
  • 386262 2023-004
    Material Weakness
  • 386263 2023-003
    Material Weakness
  • 386264 2023-004
    Material Weakness
  • 386265 2023-003
    Material Weakness
  • 386266 2023-004
    Material Weakness
  • 962682 2023-002
    Significant Deficiency
  • 962683 2023-002
    Significant Deficiency
  • 962685 2023-003
    Material Weakness
  • 962686 2023-004
    Material Weakness
  • 962687 2023-003
    Material Weakness
  • 962688 2023-004
    Material Weakness
  • 962689 2023-003
    Material Weakness
  • 962690 2023-004
    Material Weakness
  • 962691 2023-003
    Material Weakness
  • 962692 2023-004
    Material Weakness
  • 962693 2023-003
    Material Weakness
  • 962694 2023-004
    Material Weakness
  • 962695 2023-003
    Material Weakness
  • 962696 2023-004
    Material Weakness
  • 962697 2023-003
    Material Weakness
  • 962698 2023-004
    Material Weakness
  • 962699 2023-003
    Material Weakness
  • 962700 2023-004
    Material Weakness
  • 962701 2023-003
    Material Weakness
  • 962702 2023-004
    Material Weakness
  • 962703 2023-003
    Material Weakness
  • 962704 2023-004
    Material Weakness
  • 962705 2023-003
    Material Weakness
  • 962706 2023-004
    Material Weakness
  • 962707 2023-003
    Material Weakness
  • 962708 2023-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $14.39M
14.850 Public and Indian Housing $2.43M
14.872 Public Housing Capital Fund $1.53M
14.871 Covid-19 - Section 8 Housing Choice Vouchers $250,061
14.267 Continuum of Care Program $30,825
14.896 Family Self-Sufficiency Program $18,987