CUYAHOGA METROPOLITAN HOUSING AUTHORITYLocal Government

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster - Section 8 Housing Choice Vouchers / Mainstream Vouchers Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: OH003 - 2024 Award Period: January 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Housing Quality Standard (HQS) Quality Control inspections must be drawn from recently completed HQS inspections (i.e. performed during the three months preceding reinspection) (24 CFR 982.405(b)). Condition: During our testing of 22 quality control reinspections, we noted that two quality control reinspections were performed more than three months after the initial inspection. Questioned costs: Unknown Context: Testing of 22 Housing Voucher Cluster tenant files identified an exception in two files. In these instances, the quality control reinspections were not drawn from recently completed HQS inspections. Cause: We have revised our QC inspection instance generation process to ensure the 90-day window does not calculate based on the batch scheduling date but rather on the actual date of the inspection being reviewed. Going forward, any QC-related inspection that is conducted outside of the three-month compliance period will be excluded from sampling. Effect: The Authority is not in compliance with HUD guidelines for HQS requirements. Repeat Finding: No Recommendation: We recommend the Authority review their process for scheduling quality control reinspections to ensure they are performed timely. Views of responsible officials: CMHA would like to note that the 2024 sample size for QC for SEMAP compliance is approximately 95-100 inspections. Nonetheless, CMHA’s contracted vendor conducted over 170 QC inspections in 2024 and scheduled nearly double that amount. We are on track to far exceed the volume required by SEMAP sampling again this year. The team continues to review our inspections processes to ensure compliance with HQS guidelines and requirements.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation / Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.856/14.182 Federal Award Identification Number and Year: OH003 - 2023 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The PHA or owner must provide housing that is decent, safe, and sanitary, To achieve this end, the PHA or owner must perform housing quality inspections at the time of initial occupancy and at least annually thereafter to ensure that the units are decent, safe and sanitary (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123 and 886.323). Condition: During our testing of 40 tenant files for housing quality standard (HQS) requirements, we noted that 5 tenants selected did not have a HQS inspection performed annually. Questioned costs: Unknown Context: Testing of 40 Section 8 Project-Based Cluster tenant files identified an exception in 5 files. In these instances, the tenants had not had an annual HQS inspection. Cause: During the audited period, the Authority underwent a generational change in its system of record, changed inspection vendors, experienced a fifty percent turnover in the inspections in-house team and processed an unprecedented volume of HQS in-person inspections required by HUD as it emerged from COVID pandemic waivers. Since 2023, the inspections team is reviewing our inspections processes to ensure compliance with HQS guidelines and requirements. Effect: The Authority is not in compliance with HUD guidelines for HQS requirements. Repeat Finding: No Recommendation: We recommend the Authority review their process for scheduling inspections to ensure they are performed timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation / Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.856/14.182 Federal Award Identification Number and Year: OH003 - 2023 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The PHA or owner must provide housing that is decent, safe, and sanitary, To achieve this end, the PHA or owner must perform housing quality inspections at the time of initial occupancy and at least annually thereafter to ensure that the units are decent, safe and sanitary (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123 and 886.323). Condition: During our testing of 40 tenant files for housing quality standard (HQS) requirements, we noted that 5 tenants selected did not have a HQS inspection performed annually. Questioned costs: Unknown Context: Testing of 40 Section 8 Project-Based Cluster tenant files identified an exception in 5 files. In these instances, the tenants had not had an annual HQS inspection. Cause: During the audited period, the Authority underwent a generational change in its system of record, changed inspection vendors, experienced a fifty percent turnover in the inspections in-house team and processed an unprecedented volume of HQS in-person inspections required by HUD as it emerged from COVID pandemic waivers. Since 2023, the inspections team is reviewing our inspections processes to ensure compliance with HQS guidelines and requirements. Effect: The Authority is not in compliance with HUD guidelines for HQS requirements. Repeat Finding: No Recommendation: We recommend the Authority review their process for scheduling inspections to ensure they are performed timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation / Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.856/14.182 Federal Award Identification Number and Year: OH003 - 2023 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The PHA or owner must provide housing that is decent, safe, and sanitary, To achieve this end, the PHA or owner must perform housing quality inspections at the time of initial occupancy and at least annually thereafter to ensure that the units are decent, safe and sanitary (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123 and 886.323). Condition: During our testing of 40 tenant files for housing quality standard (HQS) requirements, we noted that 5 tenants selected did not have a HQS inspection performed annually. Questioned costs: Unknown Context: Testing of 40 Section 8 Project-Based Cluster tenant files identified an exception in 5 files. In these instances, the tenants had not had an annual HQS inspection. Cause: During the audited period, the Authority underwent a generational change in its system of record, changed inspection vendors, experienced a fifty percent turnover in the inspections in-house team and processed an unprecedented volume of HQS in-person inspections required by HUD as it emerged from COVID pandemic waivers. Since 2023, the inspections team is reviewing our inspections processes to ensure compliance with HQS guidelines and requirements. Effect: The Authority is not in compliance with HUD guidelines for HQS requirements. Repeat Finding: No Recommendation: We recommend the Authority review their process for scheduling inspections to ensure they are performed timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation / Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.856/14.182 Federal Award Identification Number and Year: OH003 - 2023 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The PHA or owner must provide housing that is decent, safe, and sanitary, To achieve this end, the PHA or owner must perform housing quality inspections at the time of initial occupancy and at least annually thereafter to ensure that the units are decent, safe and sanitary (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123 and 886.323). Condition: During our testing of 40 tenant files for housing quality standard (HQS) requirements, we noted that 5 tenants selected did not have a HQS inspection performed annually. Questioned costs: Unknown Context: Testing of 40 Section 8 Project-Based Cluster tenant files identified an exception in 5 files. In these instances, the tenants had not had an annual HQS inspection. Cause: During the audited period, the Authority underwent a generational change in its system of record, changed inspection vendors, experienced a fifty percent turnover in the inspections in-house team and processed an unprecedented volume of HQS in-person inspections required by HUD as it emerged from COVID pandemic waivers. Since 2023, the inspections team is reviewing our inspections processes to ensure compliance with HQS guidelines and requirements. Effect: The Authority is not in compliance with HUD guidelines for HQS requirements. Repeat Finding: No Recommendation: We recommend the Authority review their process for scheduling inspections to ensure they are performed timely. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Public and Indian Housing Assistance Listing Number: 14.850 Federal Award Identification Number and Year: 2022 Award Period: January 1, 2022 through December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). Per 24 CFR part 5, the Authority must obtain documentation and verification of citizenship and eligible immigration status for all household members. Condition: During our testing of 40 tenant files for eligibility requirements, the Authority was unable to locate complete support for 1 tenant file. They were unable to locate the following: - Birth certificates for all dependents - Declaration 214 form for all members of the household - Copy of the completed annual recertification checklist Additionally, the third party support provided for their wages did not agree to the wages listed on the HUD-50058. Questioned costs: $31 Context: Testing of 40 Public and Indian Housing tenant files identified an exception in 1 file. In this instance, the file did not contain full support for the recertification tested and did not have income support that matched the income listed in the HUD-50058. Cause: The one instance of missing information and support out of the forty tenant files sampled was contributed to by staffing transition together with COVID dynamics, and the corresponding regulatory waivers, where families self-certified annual income and family composition or were orally interviewed as opposed to in-person interviews with full verification of reported family circumstances with documented support. This nearly two-year period where full verification was not required resulted in unintended consequences and a changed tenant dynamic once the regulatory waivers expired at the close of 2021. Additionally, significant staff turnover resulted in employees hired during the COVID waiver period having to adjust to the guidelines which, though they existed previously, were not effective during their tenure. Stated clearly, some of these individuals had never conducted recertifications in the pre-COVID process. This transition compounded the problem, and while human error may have also been a factor in this instance, going forward the Authority expects to meet the recertification requirements. Effect: The Authority is not in compliance with HUD guidelines for family reexaminations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure all necessary documentation is maintained and accurate. Views of responsible officials: There is no disagreement with the audit finding.

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