Milton Housing Authority

Finding No. 2024-001 – Special Tests and Provisions; Significant Deficiency (HCV Cluster #14.871 and #14.879) CONDITION: The Authority’s Section 8 Housing Choice Vouchers program changed bank accounts during 2024 and failed to enter into a general depository agreement in accordance with HUD regulations. CRITERIA: Federal funds held in the Section 8 Housing Choice Vouchers program are required to enter into general depository agreements with their financial institutions to serve as safeguards for federal funds and provide third party rights to HUD. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: No general depository agreement form was signed between the bank and the Authority. EFFECT: The federal funds CAUSE: The overall cause was a lack of quality control in understanding the importance of entering into a general depository agreement with their financial institution for federal funds. RECOMMENDATION: The Housing Authority should implement greater oversight over the Housing Choice Voucher Program compliance requirements and train employees on procedures mandated by HUD.

Finding No. 2024-002 – Reporting; Significant Deficiency (HCV Cluster #14.871 and #14.879) CONDITION: During a HUD Compliance Review performed in 2023, the results of several indicators of the Section 8 Management Assessment Program (SEMAP) were changed resulting in the Authority being designated as a Troubled Performer. As of December 31, 2024, The Authority continued its designation of a Troubled Performer. CRITERIA: When the Authority conducts its SEMAP, it should be properly documented how they selected sample sizes and the methods that were used to ensure that the items being tested were properly calculated. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: Several indicators were adjusted to reflect a score of 0, resulting in a Troubled Performer designation for fiscal year 2023 and 2024. EFFECT: By not properly conducting and documenting the SEMAP, the Housing Authority is labeled as a Troubled Performer. Additionally, the SEMAP is a good control tool to ensure that the HCV program is being conducted in accordance with HUD regulations. CAUSE: The overall cause was a lack of quality control in performing the SEMAP. RECOMMENDATION: The Housing Authority should develop better internal controls over the performance and documentation of SEMAP or consider outsourcing this to a reputable third party.

Finding No. 2024-003 – Special Tests and Provisions; Significant Deficiency (HCV Cluster #14.871 and #14.879) CONDITION: The Authority’s Section 8 Housing Choice Vouchers program does not have a board adopted Administrative Plan that reflects the order of preference of selecting applicants off the waiting list from the Mainstream Program. CRITERIA: When the Authority is awarded Mainstream vouchers, these vouchers must be used for new admissions to the program from the waiting list. The Authority must lease these vouchers by pulling the first Mainstream-eligible family from its tenant-based waiting list. The Authority is not permitted to reassign existing participants to the program in order to make regular tenant-based vouchers available. Further, the Authority may not skip over Mainstream-eligible families on the waiting list because the Authority is serving the required number of Mainstream families. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: A review of the Authority’s Administrative Plan revealed it has not been updated to reflect how Mainstream applicants are selected from the waiting list and at what preference. EFFECT: The Housing Authority could be admitting applicants not in the preferred order. CAUSE: The overall cause was a lack of quality control in understanding the importance of waiting list selections in accordance with preference structure of the Mainstream Program. RECOMMENDATION: The Housing Authority should adopt a board-approved Administrative Plan that properly defines how applicants are selected from the waiting list.

Finding No. 2023-001 - Tenant Eligibility; Significant Deficiency (HCV Cluster #14.871 and #14.879) CONDITION: The Authority's Section 8 Housing Choice Vouchers program had a file missing form HUD-9886, authorization for release of information, for participants in accordance with HUD regulations. CRITERIA: Participants in the Section 8 Housing Choice Vouchers program are required to sign a HUD-9886 form authorizing release of information, in accordance with appropriate laws and regulations governing the program. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: Forty tenant files were chosen using a statically valid sample. Of the forty tenant files examined, one fi le did not include form HUD-9886. EFFECT: The Housing Authority could be accessing tenant information without proper tenant consent. CAUSE: The overall cause was a lack of quality control in understanding the importance of maintaining these intake documents across the life of the residents' files RECOMMENDATION: The Housing Authority should implement greater oversight over the Housing Choice Voucher Program tenant compliance requirements and train employees on procedures mandated by HUD regarding tenant eligibility.

Finding No. 2023-002 - Reporting; Significant Deficiency (HC~ Cluster #14.871 and #14.879) CONDITION: During a HUD Compliance Review, the results of several indicators of the Section 8 Management Assessment Program_{SEMAP) were changed resulting in the Authority being designated as a Troubled Performer. CRITERIA: When the Authority conducts its SEMAP, it should be properly documented how they selected sample sizes and the methods that were used to ensure that the items being tested were properly calculated. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT; Several indicators were adjusted to reflect a score of 0, resulting in a Troubled Performer designation for fiscal year 2023. EFFECT: By not properly conducting and documenting the SEMAP, the Housing Authority is labeled as a Troubled Performer. Additionally, the SEMAP is a good cqntrol tool to ensure that the HCV program is being conducted In accordance with HUD regulations. CAUSE: The overall cause was a lack of quality control in performing the SEMAP. RECOMMENDATION: The Housing Authority should develop better internal controls over the performance and documentation of SEMAP or consider outsourcing this to a reputable third party.

Finding No. 2023-003 - Special Tests and Provisions; Significant Deficiency (HCV Cluster #14.871 and #14.879) CONDITION: The Authority's Section 8 Housing Choice Vouchers program does not have a board adopted Administrative Plan that reflects the order of preference of selecting applicants off the waiting list from the Mainstream Program. CRITERIA: When the Authority is awarded Mainstream vouchers, these vouchers must be used for new admissions to the program from the waiting list. The Authority must lease these vouchers by pulling the first Mainstream-eligible family from its tenant-based waiting list. The Authority is not permitted to reassign existing participants to the program in order to make regular tenant-based vouchers available. Further, the Authority may not skip over Mainstream-eligible families on the waiting list because the Authority is serving the required number of Mainstream families. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: A review of the Authority's Administrative Plan revealed it has not been updated to reflect how Mainstream applicants are selected from the waiting list and at what preference. EFFECT: The Housing Authority could be admitting applicants not in the preferred order. CAUSE: The overall cause was a lack of quality control in understanding the importance of waiting list selections in accordance with preference structure of the Mainstream Program. RECOMMENDATION: The Housing Authority should adopt a board-approved Administrative Plan that properly defines how applicants are selected from the waiting list.

Finding No. 2023-004 - Reporting; Significant Deficiency (All Federal Programs) CONDITION: The Authority failed to submit audited financial statements electronically into the Real Estate Assessment Center (REAC) within nine (9) months after its fiscal year end. CRITERIA: Public Housing Authorities are required to ensure that audited financial statements are electronically submitted to REAC within 9 months after its fiscal year end. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: The Authority lacked proper urgency and diligence to ensure that REAC deadlines were met. CAUSE: The overall cause was a lack of quality control in understanding the importance of meeting all deadlines required by HUD. EFFECT: The Authority was unable to submit the audited financial statements into REAC within the required deadline. RECOMMENDATION: No recommendation. This occurred under prior Authority management.

Finding No. 2023-005 - Allowable Costs/Cost Principles; Significant Deficiency (#14.896 - Family Self Sufficiency Program) CONDITION: The Authority was improperly administering the Family Self Sufficiency program by failing to account for the FSS funds provided to the Authority that has been contracted to administer the program on behalf of Milton Housing Authority. Additionally, the Authority was improperly reimbursing itself with FSS funds. CRITERIA: When the Authority is awarded Family Self Sufficiency funds, these funds are only allowed to be used for reimbursable FSS activities in accordance with program guidelines. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: It was discovered that the Authority was not overseeing the FSS funds disbursed to the Brockton Housing Authority to administer the FSS program for the Authority. Additionally, .the Authority was reimbursing itself with FSS funds that is not believed to be in accordance with allowable reimbursable FSS activities. CAUSE: The overall cause was a lack of quality control in understanding the program guidelines and reimbursable activities. EFFECT: The Housing Authority could be using FSS funds for unallowable costs. RECOMMENDATION: The Housing Authority should review FSS program guidelines and reimbursable activities to ensure that it is properly disbursing FSS funds.

Finding No. 2021-001 ? Tenant Eligibility; Significant Deficiency CONDITION: The Authority?s Section 8 Housing Choice Vouchers program had several missing Section 214 Declaration of Citizenship forms and proof of citizenship for participants in accordance with HUD regulations. CRITERIA: Participants in the Section 8 Housing Choice Vouchers program are required to be citizens of the United States and affirm this with a signed Section 214 declaration, in accordance with appropriate laws and regulations governing the program. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: Forty tenant files were chosen using a statically valid sample. Of the forty tenant files examined, three files did not include 214 declarations. Two of these three files also did not contain any documentation corroborating citizenship status (i.e., social security card, birth certificates, naturalization certificates). EFFECT: The Housing Authority could be providing access to vouchers to tenants who do not meet eligibility criteria for the program. CAUSE: The overall cause was a lack of quality control in understanding the importance of maintaining these intake documents across the life of the residents? files RECOMMENDATION: The Housing Authority should implement greater oversight over the Housing Choice Voucher Program tenant compliance requirements and train employees on procedures mandated by HUD regarding tenant citizenship eligibility.

Finding No. 2020-001 - Tenant Eligibility; Significant Deficiency CONDITION: The Authority's Section 8 Housing Choice Vouchers program had several missing Enterprise Income Verification (EIV) forms for new tenants in accordance with HUD regulations. CRITERIA: New tenants of the Section 8 Housing Choice Vouchers program are required to be processed through the Enterprise Income Verification system within 120 days of their move-in date. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: Forty tenant files were chosen using a statically valid sample. Of the forty tenant files examined, two files did not include move-in EIVs. EFFECT: The Housing Authority could be providing access to vouchers to tenants who do not meet eligibility criteria for the program. CAUSE: The overall cause was a lack of quality control in understanding the policy of EIVs surrounding select changes due to the COVID-19 pandemic. RECOMMENDATION: The Housing Authority should implement greater oversight over the Housing Choice Voucher Program tenant compliance requirements and train employees on procedures mandated by HUD regarding tenant income, verification, and annual recertification.

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