EIN: 446000716
UEI: HBL6DQ3NT6G8
Audited by: CliftonLarsonAllen LLP
Cognizant agency: 14 [Department of Housing and Urban Development]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 30, 2026 (156 days ago).
What is a management decision? →The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 6 out of 60 files tested for eligibility requirements. The Authority was unable to provide supporting documentation that 5 tenants were recertified timely. The Authority was unable to provide 1 file. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements. Effect: The Authority is not in compliance with eligibility requirements. Repeat Finding: Yes, finding 2023-001. Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Eligibility Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 6 out of 60 files tested for eligibility requirements. The Authority was unable to provide supporting documentation that 5 tenants were recertified timely. The Authority was unable to provide 1 file. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements. Effect: The Authority is not in compliance with eligibility requirements. Repeat Finding: Yes, finding 2023-001. Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC has moved to mass annual recertification appointments to address the program delinquency and inspect files for required documentation; the recertifications will be completed and processed ensuring all documentation has been received in the file. HAKC will perform a QC sample on a monthly basis to address the files and ensure proper documentation. In addition to QC samples, the HAKC has awarded a QC contract to audit 100% of the files. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/31/2026
2023-001
The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908. Questioned costs: Unable to determine. Context: Exceptions noted in 7 out of 60 recertifications. In 4 instances, the Housing Assistance Payment per the HUD-50058 did not agree to the PIC system. In 3 instances, the recertification was not located in the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system. Effect: The Authority is not in compliance with PIC reporting requirements. Repeat Finding: Yes, finding 2023-002. Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908). Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908. Questioned costs: Unable to determine. Context: Exceptions noted in 7 out of 60 recertifications. In 4 instances, the Housing Assistance Payment per the HUD-50058 did not agree to the PIC system. In 3 instances, the recertification was not located in the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system. Effect: The Authority is not in compliance with PIC reporting requirements. Repeat Finding: Yes, finding 2023-002. Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will monitor the monthly SEMAP Indicator report and monitor the PIC dashboard to ensure all 50058 errors are corrected and uploaded in a timely manner. HAKC will also pull the ADHOC from PIC to verify the records. HAKC will continue working with the HUD PIC coach monthly to correct all errors. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 4/30/2026
2023-002
The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 5 out of 12 files tested for reasonable rent requirements. Adequate supporting documentation was not maintained. Exceptions noted in 1 out of 60 new tenants. The file was not able to be located. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness. Effect: The Authority is not in compliance with rent reasonableness requirements. Repeat Finding: Yes, finding 2023-003. Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 5 out of 12 files tested for reasonable rent requirements. Adequate supporting documentation was not maintained. Exceptions noted in 1 out of 60 new tenants. The file was not able to be located. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness. Effect: The Authority is not in compliance with rent reasonableness requirements. Repeat Finding: Yes, finding 2023-003. Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will audit files for the correct methodology used in determining rents and ensure rents are reasonable on a monthly basis. In addition, HAKC has contracted a QC audit to review 100% of the files. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/31/2026
2023-003
The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Unable to determine. Context: Exceptions were noted in 14 out of 60 failed inspections. The Authority did not properly abate HAP for 11 out of 60 failed inspections. Adequate supporting documentation was not provided for 3 files. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: Yes, finding 2023-004. Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Unable to determine. Context: Exceptions were noted in 14 out of 60 failed inspections. The Authority did not properly abate HAP for 11 out of 60 failed inspections. Adequate supporting documentation was not provided for 3 files. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: Yes, finding 2023-004. Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will conduct Quality Control on 20% of failed inspections on a biweekly basis to ensure abatements are not missed before the cutoff date of the 27th of each month. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 1/31/2026
2023-004
The Authority did not ensure the HAP per the HUD-50058 was properly reflected in the HAP contract and HAP register. Questioned costs: Unable to determine. Context: Exceptions were noted in 5 out of 40 tenant files. 12u of the HUD-50058 did not agree to the HAP contract and HAP register for 4 files. 1 file was unable to be located. Cause: The Authority did not ensure that the HUD-50058, HAP contract, and HAP register agree. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: No Recommendation: We recommend the Authority implements controls to ensure the HAP agrees between the HUD-50058, HAP contract, and HAP register. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Housing Assistance Payment (HAP) Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not ensure the HAP per the HUD-50058 was properly reflected in the HAP contract and HAP register. Questioned costs: Unable to determine. Context: Exceptions were noted in 5 out of 40 tenant files. 12u of the HUD-50058 did not agree to the HAP contract and HAP register for 4 files. 1 file was unable to be located. Cause: The Authority did not ensure that the HUD-50058, HAP contract, and HAP register agree. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: No Recommendation: We recommend the Authority implements controls to ensure the HAP agrees between the HUD-50058, HAP contract, and HAP register. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure the HAP agrees between the HUD-50058, HAP contract, and HAP register. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will take the necessary steps to ensure the HUD-50058 matches the HAP contract and the HAP register by reviewing the accuracy of HAP amount, coordinate general HAP processing controls, (segregating duties to mitigate the threat of fraud or theft), and monitoring files on a monthly basis. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 3/31/2026
The Authority was unable to provide support for 1 new tenant. Questioned costs: Unable to determine. Context: Exceptions were noted in 1 out of 40 files. Cause: The file was unable to be located. Effect: The Authority is not in compliance with new tenant admission requirements. Repeat Finding: No Recommendation: We recommend the Authority implements controls to ensure all files are maintained and available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Selection from the Waiting List - New Tenants Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: The Authority was unable to provide support for 1 new tenant. Questioned costs: Unable to determine. Context: Exceptions were noted in 1 out of 40 files. Cause: The file was unable to be located. Effect: The Authority is not in compliance with new tenant admission requirements. Repeat Finding: No Recommendation: We recommend the Authority implements controls to ensure all files are maintained and available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure all files are maintained and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will take the necessary steps to ensure files are placed back in the file room and are available upon request with the required documentation placed in the file. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 7/31/2026
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements. Effect: The Authority is not in compliance with eligibility requirements. Repeat Finding: Yes, finding 2022-001. Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023 Compliance Requirement: Eligibility Type of Finding: • Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). The Authority must determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 3 out of 60 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information for 1 file. The Authority was unable to provide supporting documentation that 2 tenants were recertified timely. Cause: The Authority did not maintain supporting documentation within the tenant file and did not complete all recertifications in accordance with eligibility requirements. Effect: The Authority is not in compliance with eligibility requirements. Repeat Finding: Yes, finding 2022-001. Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Views of responsible officials: There is no disagreement with the audit finding.
Response to Finding 2023-001 The Authority generally concurs with the auditor’s findings and recommendations. To address these issues, the Authority has implemented the following corrective actions: 1. Mandatory Refresher Training: • Effective May 2024, the Authority has rolled out mandatory refresher training for all relevant staff on eligibility documentation and recertification processes. This training ensures that all staff are fully aware of the correct procedures and policies, and that they understand the importance of maintaining complete and accurate tenant files and performing recertifications in a timely manner. 2. Implementation of a New Tracking System: • A new tracking system has been implemented to ensure that all documentation is completed timely and verified by a supervisor. This system allows for real-time monitoring of the documentation process, ensuring that all required documents are included in the tenant files. 3. Utilization of Checklists: • The Authority has introduced a mandatory checklist that staff are required to use every time a file is accessed or updated. This checklist serves as a tool to ensure that all necessary steps are taken, and all required documentation is included in the tenant file. 4. Enhanced Monitoring by HCV Director and Supervisors: • The HCV Director and Supervisors will closely monitor the recertification process to ensure that all recertifications are completed in a timely manner and in accordance with policy. This includes ensuring that all participants receive and return their recertification paperwork as required. 5. Increased Frequency of Quality Control Reviews: • The Authority will continue to conduct quality control file reviews and will increase the frequency of these reviews to identify errors sooner. This proactive approach will help address the root causes of errors quickly and prevent systemic issues from developing. 6. Ongoing Quality Reviews: • Continuous quality reviews will be conducted for all files to ensure that all required documents are present and that all recertifications are performed on time. This ongoing process is designed to maintain high standards of accuracy and compliance in tenant file management. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024
2022-001
The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908. Questioned costs: Unable to determine. Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system. Effect: The Authority is not in compliance with PIC reporting requirements. Repeat Finding: Yes, finding 2022-002. Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023 Compliance Requirement: Reporting – PIH Information Center (PIC) Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908). Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908. Questioned costs: Unable to determine. Context: Exceptions noted in 2 out of 60 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system. Effect: The Authority is not in compliance with PIC reporting requirements. Repeat Finding: Yes, finding 2022-002. Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Views of responsible officials: There is no disagreement with the audit finding.
Response to Finding 2023-002 The Authority generally concurs with the auditor’s findings and recommendations. The Authority has implemented procedures to ensure recertifications are promptly uploaded to the PIC system. Effective August 2024, we have adopted a system that flags any recertification not uploaded to PIC. A HAKC Quality Control employee is responsible for daily uploads from Monday through Friday. With each upload, any fatal errors encountered are documented in an Excel spreadsheet. Once the error has been corrected in the PIC system, the correction is recorded on the spreadsheet, and the corresponding green status from PIC is printed for documentation, confirming that the issue has been resolved. To maintain ongoing compliance, bi-weekly audits will be conducted to verify that no files are missing from the PIC system. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024
2022-002
The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness. Effect: The Authority is not in compliance with rent reasonableness requirements. Repeat Finding: Yes, finding 2022-004. Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding:Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the Housing Assistance Payment (HAP) contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 40 files tested for reasonable rent requirements. Documentation for the determination of rent was not maintained for the 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness. Effect: The Authority is not in compliance with rent reasonableness requirements. Repeat Finding: Yes, finding 2022-004. Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Views of responsible officials: There is no disagreement with the audit finding.
Response to Finding 2023-003 The Authority generally concurs with the auditor’s findings and recommendations. To address the finding related to inadequate documentation for rent reasonableness determinations, the Authority will implement the following corrective actions: 1. Immediate and Ongoing Training: • To ensure consistency, increase staff knowledge, and reduce errors, the Authority will conduct immediate training sessions for all relevant staff, followed by annual refresher training. These sessions will focus on the correct procedures for documenting rent reasonableness and the importance of maintaining accurate and complete records. 2. Enhanced Quality Control and Error Monitoring: • The Authority will increase the frequency of quality control file reviews to identify errors promptly and address their root causes to prevent systemic issues. • Errors will be tracked by type and by the staff member responsible, allowing for the identification of patterns. Additional training will be provided for common error types and to individuals who are frequently responsible for errors. 3. Comprehensive File Reviews: • Quality reviews will be conducted on all files to ensure the presence of all required documents. It is anticipated that the initial comprehensive file review will take approximately one year to complete. • After the initial review, files will be selected randomly for review according to an established quality control schedule. This ongoing review process will ensure continuous compliance and address any issues as they arise. 4. Responsibility for Document Collection: • Each team member will be responsible for collecting any missing documents identified during the annual recertification, interim recertification, or change of unit processes. This accountability measure ensures that all necessary documentation is gathered and maintained consistently. 5. Adoption of a Digital Platform: • As part of the corrective action, the Authority has adopted a digital platform that requires the completion of all necessary fields before a rent determination can be finalized. This platform will also retain all documentation used to determine rent reasonableness for at least two years, ensuring thorough and accessible records. 6. Increased Random Audits: • Effective October 2024, random audits will be increased to monthly reviews to identify any discrepancies early and to ensure ongoing compliance with documentation requirements. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024
2022-003
The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs. Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: Yes, finding 2022-005. Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2023 Award Period: January 1, 2023 – December 31, 2023 Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Type of Finding: Significant Deficiency in Internal Control over Compliance Type of Finding: Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $3,500 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs. Context: Exceptions were noted in 1 out of 60 failed inspections. The Authority did not properly abate HAP for 1 out of 60 failed inspections. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: Yes, finding 2022-005. Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding.
Response to Finding 2023-004 The Authority generally concurs with the auditor’s findings and recommendations regarding the handling of HQS deficiencies. To address this, the Authority will implement a more rigorous process to ensure timely correction of deficiencies and adherence to abatement procedures. 1. Enhanced Correction Process: • Effective October 2024, the Authority will introduce stricter timelines and automated reminders for staff to manage I IQS deficiencies. • Tf a deficiency is not corrected within the timeframe specified in the HAKC HCV Admin Plan, it will automatically escalate to the HCV Inspection Manager and Supervisor for immediate action. • Immediate actions include placing the unit on hold in the Elite system, issuing a notice to the landlord and participant, and sending an email to the Specialist to issue a voucher for the participant to move, if necessary. • A formal letter will be sent to both the landlord and tenant notifying them of the identified deficiencies, along with a set timeframe of 30 days for the repairs to be completed. A re-inspection date will be scheduled to verify that repairs have been made. 2. Abatement Process: • If repairs are not made by the set re-inspection date, an abatement letter will be sent to both the landlord and tenant, notifying them that HAP payments will cease on the first day of the following month, providing a minimum of 30 days' notice. • At this time, a letter will also be sent to the tenant notifying them that a voucher will be issued to allow them to move to a more suitable unit. 3. Termination of HAP Contract: • If repairs are still not completed by the end of the 30-day abatement period, the HAP contract will be terminated along with the HAP payment. A termination of HAP letter will be sent to the landlord and tenant for the current unit. 4. Documentation and Review Process: • The Inspection Department will maintain a weekly abatement spreadsheet documenting the reason for abatement, the start and end dates of the abatement, and any associated inspection reports. • This spreadsheet, along with the abated inspection documentation, will be reviewed at the beginning and end of each month before closeout to ensure that the abatement process is properly initiated and managed. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024 If the Department of Housing and Urban Development has questions regarding this plan, please call LaMonyka French, Deputy, Executive Director at (816) 968-4100.
2022-004
FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.
The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 40 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information or third party verification of reported family annual income, the value of assets, or expenses related to deductions from annual income. The sample was statistically valid. Cause: The Authority did not maintain supporting documentation within the tenant file. Effect: The Authority is not in compliance with eligibility requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Eligibility Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). The Authority must determine income eligibility and calculate the tenant?s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition: The Authority was unable to provide adequate supporting documentation and evidence of internal control over compliance for eligibility requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 40 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information or third party verification of reported family annual income, the value of assets, or expenses related to deductions from annual income. The sample was statistically valid. Cause: The Authority did not maintain supporting documentation within the tenant file. Effect: The Authority is not in compliance with eligibility requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Eligibility Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Condition: Exceptions noted in 1 out of 40 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information or third-party verification of reported family annual income, the value of assets, or expenses related to deductions from annual income. Cause: The Authority did not maintain supporting documentation within the tenant file. Auditor?s Recommendations: Recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Response to Finding 2022-001 The Authority generally concurs with the auditor?s findings and recommendations. The 2022 Audit included the review of 40 HCV files and deficiencies were noted in only one file. The Authority was unable to provide documentation for releases of information or third-party verification of reported family annual income, the value of assets, or expenses related to deductions from annual income. Action Taken: The implementation of a Corrective Action Plan to address the errors to ensure that the tenant files include all required documentation at the time of recertification began on August 1, 2023. To provide consistency, increase staff knowledge and reduce errors, training began immediately and will continue on an annual and as needed basis. In addition, HAKC will increase quality control file reviews and conduct such reviews on a more frequent basis to identify errors sooner and address the cause of errors quickly to prevent systemic errors. Errors will be identified by error type and the person who made the error. Patterns of errors will be monitored, and additional training provided for similar error types that are frequently repeated and persons who are identified as frequently making errors. Quality reviews will be conducted for all files to ensure that all required documents are in the files. It is anticipated it will take one year to complete the initial file review. After the initial review files will be selected randomly and reviewed according to an established quality control schedule. Each team member will be responsible to collect missing documents identified when completing an annual recertification, interim recertification or change of unit. The Director and Supervisor will assist the Deputy Executive Director and Executive Director in overseeing these corrective actions during the next fiscal year. Name of the contact person responsible for corrective action: Edwin Lowndes Executive Director Planned completion date for corrective action plan to be fully implemented: March 1, 2024.
The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908. Questioned costs: Unable to determine. Context: Exceptions noted in 4 out of 40 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. The sample was statistically valid. Cause: The Authority did not identify recertifications that failed to upload to the PIC system. Effect: The Authority is not in compliance with PIC reporting requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Reporting ? PIH Information Center (PIC) Reporting Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Authority is required to submit the HUD-50058 electronically to HUD via the PIH Information Center (PIC) each time the Authority completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908). Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908. Questioned costs: Unable to determine. Context: Exceptions noted in 4 out of 40 recertifications. In all instances, the HUD-50058 was unable to be located within the PIC system. The sample was statistically valid. Cause: The Authority did not identify recertifications that failed to upload to the PIC system. Effect: The Authority is not in compliance with PIC reporting requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Reporting ? PIH Information Center (PIC) Reporting Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Condition: The Authority did not satisfy PIC reporting requirements in accordance with 24 CFR Part 908. Exceptions were noted in 4 out of 40 recertifications. In each of the four instances, the HUD-50058 was unable to be located within the PIC system. Cause: The Authority did not identify recertifications that failed to upload to the PIC system. Auditor?s Recommendations: Recommend that the Authority implement controls to ensure HUD-50058 recertifications are uploaded to PIC. Response to Finding 2022-002 The Authority generally concurs with the auditor?s findings and recommendations. The 2022 Audit included the review of 40 Recertifications and identified four instances where the HUD- 50058 was not located within the PIC system. Action Taken: A Corrective Action Plan has been developed to ensure HUD-50058 recertifications are uploaded to PIC. Implementation began on August 1, 2023. To provide consistency, the plan is to upload the HUD-50058 sixty days in advance of the recertification date. HAKC will upload the HUD-50058 every week to ensure recertifications are registered in PIC. In addition, we will increase quality control file reviews and conduct such reviews on a more frequent basis to identify errors sooner and address the cause of errors quickly to prevent systemic errors. Errors will be identified by error type and the person who made the error. Patterns of errors will be monitored, and additional training provided for similar error types that are frequently repeated and persons who are identified as frequently making errors. Name of the contact person responsible for corrective action: Edwin Lowndes Executive Director. Planned completion date for corrective action plan: March 1, 2024.
The Authority did not ensure the monthly HAP payment agreed between the HUD-50058, HAP contract, and HAP register in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 2 out of 40 files tested for Housing Assistance Payments. In both instances, the HAP register did not agree to the HUD-50058 and HAP contract. The sample was statistically valid. Cause: The Authority did not identify variances between the HUD-50058, HAP contract, and HAP register. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure the HAP paid agrees to the HUD-50058 and HAP contract. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Housing Assistance Payment (HAP) Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Authority must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not ensure the monthly HAP payment agreed between the HUD-50058, HAP contract, and HAP register in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 2 out of 40 files tested for Housing Assistance Payments. In both instances, the HAP register did not agree to the HUD-50058 and HAP contract. The sample was statistically valid. Cause: The Authority did not identify variances between the HUD-50058, HAP contract, and HAP register. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure the HAP paid agrees to the HUD-50058 and HAP contract. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022 ? 003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Housing Assistance Payment (HAP) Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters- Condition: The Authority did not ensure the monthly HAP payment agreed between the HUD- 50058, HAP contract, and HAP register in accordance with program compliance requirements. Exceptions were noted in 2 out of 40 files tested for Housing Assistance Payments. In both instances, the HAP register did not agree to the HUD-50058 and HAP contract. Cause: The Authority did not identify variances between the HUD-50058, HAP contract, and HAP register. Auditors Recommendation: Recommend that the Authority implements controls to ensure the HAP paid agrees to the HUD-50058 and HAP contract. Response to Finding 2022-003 The Authority generally concurs with the auditor?s findings and recommendations. The 2022 Audit included the review of 40 files tested for Housing Assistance Payments. In two instances, the HAP register did not agree to the HUD-50058 and HAP contract. Action Taken: A Corrective Action Plan has been developed to ensure the HAP register agrees with the HUD 50058 and HAP contract. Implementation began on August 1, 2023. To provide consistency for the HUD 50058 HAKC will increase staff knowledge and reduce errors through training. This will be held immediately and then annually thereafter. In addition, we will increase quality control file reviews and conduct such reviews on a more frequent basis to identify errors sooner and address the cause of errors quickly to prevent systemic errors. Errors will be identified by error type and the person who made the error. Patterns of errors will be monitored, and additional training provided for similar error types that are frequently repeated and persons who are identified as frequently making errors. In regard to the HAP contract, going forward any new HAP contracts will be reviewed by the supervisor of the department before the HAP is enforced. The supervisor will sign the HAP contract if no errors are found. With this quality control in effect, the HAP contract will match the HAP register. Quality reviews will also be conducted by compliance to check the HAP contracts to make sure they comply. Name of the contact person responsible for corrective action: Edwin Lowndes Executive Director Planned completion date for corrective action plan: March 1, 2024.
The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 2 out of 80 files tested for reasonable rent requirements: ? Documentation for the determination of rent was not maintained for 1 sample. ? The contract rent did not agree to the rent determined reasonable for 1 sample. The sample was statistically valid. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness. Effect: The Authority is not in compliance with rent reasonableness requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in in accordance with rent reasonableness requirements. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Reasonable Rent Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract before any increase in the rent to owner. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 2 out of 80 files tested for reasonable rent requirements: ? Documentation for the determination of rent was not maintained for 1 sample. ? The contract rent did not agree to the rent determined reasonable for 1 sample. The sample was statistically valid. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness. Effect: The Authority is not in compliance with rent reasonableness requirements. Repeat Finding: No. Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in in accordance with rent reasonableness requirements. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022 ? 004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO ? 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Reasonable Rent Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Condition: The Authority did not perform rent reasonableness procedures in accordance with program compliance requirements. Exceptions noted in 2 out of 80 files tested for reasonable rent requirements: Documentation for the determination of rent was not maintained for 1 sample. The contract rent did not agree to the rent determined reasonable for 1 sample. Cause: The Authority did not maintain documentation utilized to determine rent reasonableness. Auditors Recommendation: Recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Response to Finding 2022-004 The Authority generally concurs with the auditor?s findings and recommendations. The 2022 Audit included the review of 80 files tested for reasonable rent requirements. Exceptions were noted in two instances, documentation for the determination of rent was not maintained for 1 sample; and the contract rent did not agree to the rent determined reasonable for 1 sample. Action Taken: A Corrective Action Plan has been developed to ensure that documentation is maintained in accordance with rent reasonableness requirements. Implementation began on August 1, 2023. To provide consistency, increase staff knowledge and reduce errors, training will be held immediately and then annually thereafter. In addition, HAKC will increase quality control file reviews and conduct such reviews on a more frequent basis to identify errors sooner and address the cause of errors quickly to prevent systemic errors. Errors will be identified by error type and the person who made the error. Patterns of errors will be monitored, and additional training provided for similar error types that are frequently repeated and persons who are identified as frequently making errors. Quality reviews will be conducted for all files to ensure that all required documents are in the files. It is anticipated it will take one year to complete the initial file review. After the initial review files will be selected randomly and reviewed according to an established quality control schedule. Each team member will be responsible to collect missing documents identified when completing an annual recertification, interim recertification or change of unit. Name of the contact person responsible for corrective action: Edwin Lowndes Executive Director Planned completion date for corrective action plan: March 1, 2024.
The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $20,539 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs. Context: Exceptions were noted in 9 out of 40 failed inspections: ? The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 2 out of 40 failed inspections. ? The Authority did not properly abate HAP for 7 out of 40 failed inspections. The sample was statistically valid. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Housing Quality Standards (HQS) Enforcement Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family?s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Questioned costs: Known questioned costs of $20,539 were calculated based on the HAP payment for the units that should have been abated, multiplied by the number of months where HAP was incorrectly paid. Unable to determine likely questioned costs. Context: Exceptions were noted in 9 out of 40 failed inspections: ? The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 2 out of 40 failed inspections. ? The Authority did not properly abate HAP for 7 out of 40 failed inspections. The sample was statistically valid. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022 ? 005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Housing Quality Standards (HQS) Enforcement Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Condition: The Authority did not require HQS deficiencies to be corrected within the required timeframe. The Authority did not abate units that failed to correct HQS deficiencies within the required timeframe. Exceptions were noted in 9 out of 40 failed inspections: The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 2 out of 40 failed inspections. The Authority did not properly abate HAP for 7 out of 40 failed inspections. Cause: The Authority did not reinspect or abate units timely. Auditors Recommendation: Recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 24 CFR section 982.404(a). Recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Response to Finding 2022-005 The Authority generally concurs with the auditor?s findings and recommendations. The 2022 Audit included the review of 40 files tested for Housing Quality Standards (HQS) Enforcement requirements. Exceptions were noted in nine instances: The Authority did not require the owner to correct HQS deficiencies within the required timeframe for 2 out of 40 failed inspections. The Authority did not properly abate HAP for 7 out of 40 failed inspections. Action Taken: A Corrective Action Plan has been developed to ensure HQS Inspection enforcement is applied at the time of deficiency and if not corrected proper abatement notice being sent out to Landlord and tenant. Implementation began on August 1, 2023. To provide consistency, increase staff knowledge and reduce errors, training will be held immediately and then annually thereafter. In addition, we will increase quality control to monitor letters being sent out to landlords and tenants for the deficiencies that occurred in the unit. The process that will be in place is as follows: 1. Letter sent out to landlord and tenant notifying them the deficiencies in the unit. A time frame of 30 days will be set for the repairs to be made with a re-inspection date already set to verify repairs. 2. If the repairs are not made at that time, an abatement a letter will be sent out to the landlord and tenant notifying them that the HAP payment will stop the first day of the following month which would be a minimum of 30 days. At this time a letter will be sent to the tenant notifying them that a voucher will be issued to them to move to a more suitable unit. 3. If the repairs are not made at the end of the 30-day abatement period the HAP contract will terminate along with the HAP payment. A termination of HAP letter will be sent out to the landlord and tenant for the current unit that the tenant is living in. To monitor the events taking place above, a report will be submitted twice a month before our check run by the supervisor and manager of the inspection department to the HCV Director and Compliance department to monitor the HQS and abatement process. This quality insurance will ensure that all abatements and HQS deficiencies are being processed according to compliance. Name(s) of the contact person(s) responsible for corrective action: Edwin Lowndes Executive Director Planned completion date for corrective action plan: March 1, 2024.
FAC accepted this audit on October 17, 2022 — management decision was due April 17, 2023.
FAC accepted this audit on September 29, 2021 — management decision was due March 29, 2022.
Out of a total tenant population of approximately 7,200 tenants, 40 tenant files were tested and the following deficiencies were noted in 2 files: ? One file had a late annual recertification, ? One file did not have an annual recertification performed in the previous year which made us unable to determine if the current year annual recertification was performed timely or subject to waivers, ? One file used the incorrect utility allowance. Context: The auditor randomly selected 40 tenant files out of the population, which we consider to be a statistically valid sample size, for testing tenant files for eligibility. The Auditor reviewed the tenant file and support to ensure controls over compliance were operating effectively. Criteria: The Authority?s administrative plan and 24 CFR 982.516 require that the internal controls are in place to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Effect: The Authority is not in full compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Cause: The Authority experienced staffing turnover and did not have the staff stability to fully implement the established internal controls to ensure proper compliance with regards to timely recertifications. Auditor Recommendations: The Authority should continue to follow the established procedures, systems, and internal controls to ensure full compliance in regards to eligibility. It was noted during our testing that there was a shortage of recertification specialists, that caused the delay in the recertifications. We recommend reassigning workloads based on available staffing as well as starting the recertification process sooner, which should assist with timely recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See the Corrective Action Plan in this report.
Show full finding ▾Hide full finding ▴2020-001 Eligibility U.S. Department of HUD - Housing Voucher Cluster Other matter required to be reported in accordance with Uniform Guidance Findings repeated in part from the prior year 2019-001 Condition: Out of a total tenant population of approximately 7,200 tenants, 40 tenant files were tested and the following deficiencies were noted in 2 files: ? One file had a late annual recertification, ? One file did not have an annual recertification performed in the previous year which made us unable to determine if the current year annual recertification was performed timely or subject to waivers, ? One file used the incorrect utility allowance. Context: The auditor randomly selected 40 tenant files out of the population, which we consider to be a statistically valid sample size, for testing tenant files for eligibility. The Auditor reviewed the tenant file and support to ensure controls over compliance were operating effectively. Criteria: The Authority?s administrative plan and 24 CFR 982.516 require that the internal controls are in place to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Effect: The Authority is not in full compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Cause: The Authority experienced staffing turnover and did not have the staff stability to fully implement the established internal controls to ensure proper compliance with regards to timely recertifications. Auditor Recommendations: The Authority should continue to follow the established procedures, systems, and internal controls to ensure full compliance in regards to eligibility. It was noted during our testing that there was a shortage of recertification specialists, that caused the delay in the recertifications. We recommend reassigning workloads based on available staffing as well as starting the recertification process sooner, which should assist with timely recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See the Corrective Action Plan in this report.
CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development The Housing Authority of Kansas City, Missouri respectfully submits the following corrective action plan for the year ended December 31, 2020. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP 8035 Spyglass Hill Road Melbourne, FL 32940 Audit period: January 1, 2020 ? December 31, 2020 FINDINGS - FEDERAL AWARD PROGRAMS AUDIT 2020-001 Eligibility U.S. Department of HUD - Housing Voucher Cluster Other matter required to be reported in accordance with Uniform Guidance Findings repeated in part from the prior year 2019-001 Condition: Out of a total tenant population of approximately 7,200 tenants, 40 tenant files were tested and the following deficiencies were noted in 2 files: ? One file had a late annual recertification, ? One file did not have an annual recertification performed in the previous year which made us unable to determine if the current year annual recertification was performed timely or subject to waivers, ? One file used the incorrect utility allowance. Auditor?s Recommendations: The Authority should continue to follow the established procedures, systems, and internal controls to ensure full compliance in regards to eligibility. It was noted during our testing that there was a shortage of recertification specialists, that caused the delay in the recertifications. We recommend reassigning workloads based on available staffing as well as starting the recertification process sooner, which should assist with timely recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Response to Finding involving HCV Files Action Taken: The Authority generally concurs with the auditor?s findings and recommendations. The 2020 Audit included the review of 40 HCV files and deficiencies were noted in only two files. One file had late annual recertifications; one file did not have an annual recertification performed in the previous year so it was not possible to determine if the current year?s recertification was timely or subject to waivers and one file had an incorrect utility allowance. Procedures to address the errors have been implemented and existing procedures modified to ensure that calculation and documentation related errors are reduced or eliminated to the extent possible. HAKC continues to implement its training program for new and existing personnel. This training will continue to minimize the errors. In addition, HAKC engaged a nationally recognized firm to review, evaluate and implement systems and procedural changes to minimize file deficiencies. The firm commenced work at HAKC in the first quarter of 2021. If the Department of Housing and Urban Development has questions regarding this plan, please call Edwin Lowndes, Executive Director at (816) 968-4100.
2019-001
FAC accepted this audit on December 30, 2020 — management decision was due June 30, 2021.
Out of a total tenant population of approximately 7,200 tenants, 41 tenant files were tested and the following deficiencies were noted in 6 files: ? Five files had late annual recertifications, ? One file had a late HUD 9886 release of information form. Context: The auditor randomly selected 41 tenant files out of the population, which we consider to be a statistically valid sample size, for testing tenant files for eligibility. The Auditor reviewed the tenant file and support to ensure controls over compliance were operating effectively. Criteria: The Authority?s administrative plan and 24 CFR 982.516 require that the internal controls are in place to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Effect: The Authority is not in full compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Cause: The Authority experienced staffing turnover and did not have the staff stability to fully implement the established internal controls to ensure proper compliance with regards to timely recertifications. Auditor Recommendations: The Authority should continue to follow the established procedures, systems, and internal controls to ensure full compliance in regards to eligibility. It was noted during our testing that there was a shortage of recertification specialists, that caused the delay in the recertifications. We recommend reassigning workloads based on available staffing as well as starting the recertification process sooner, which should assist with timely recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See the Corrective Action Plan in this report.
Show full finding ▾Hide full finding ▴2019-001 Eligibility U.S. Department of HUD - Housing Voucher Cluster Significant Deficiency in Internal Control Other matter required to be reported in accordance with Uniform Guidance Findings repeated in part from the prior year 2018-002 Condition: Out of a total tenant population of approximately 7,200 tenants, 41 tenant files were tested and the following deficiencies were noted in 6 files: ? Five files had late annual recertifications, ? One file had a late HUD 9886 release of information form. Context: The auditor randomly selected 41 tenant files out of the population, which we consider to be a statistically valid sample size, for testing tenant files for eligibility. The Auditor reviewed the tenant file and support to ensure controls over compliance were operating effectively. Criteria: The Authority?s administrative plan and 24 CFR 982.516 require that the internal controls are in place to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Effect: The Authority is not in full compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Cause: The Authority experienced staffing turnover and did not have the staff stability to fully implement the established internal controls to ensure proper compliance with regards to timely recertifications. Auditor Recommendations: The Authority should continue to follow the established procedures, systems, and internal controls to ensure full compliance in regards to eligibility. It was noted during our testing that there was a shortage of recertification specialists, that caused the delay in the recertifications. We recommend reassigning workloads based on available staffing as well as starting the recertification process sooner, which should assist with timely recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See the Corrective Action Plan in this report.
Actions Taken: The Authority generally concurs with the auditor?s findings and recommendations. The 2019 Audit identified 6 files with errors specific to the Housing Choice Voucher program. Five files were identified as having late annual recertifications performed; one of those files was also identified as having a late HUD 9886 form, and one file was identified as having used an incorrect utility allowance. Procedures to address the errors are being implemented or existing procedures modified to ensure that calculation and documentation related errors are reduced or eliminated to the extent possible. To provide consistency, increase staff knowledge and reduce errors, training will be held annually. New staff, staff who has had the training but failed the proficiency test and staff who are identified as having made errors by any file review or audit will be assigned to attend. In addition, we will increase quality control file reviews and conduct such reviews on a more frequent basis to identify errors sooner and address the cause of errors quickly to prevent systemic errors. Errors will be identified by error type and the person who made the error. Patterns of errors will be monitored, and additional training provided for similar error types that are frequently repeated and persons who are identified as frequently making errors. With respect to the errors relating to late documentation, a standard operating procedure that all required documents are checked every time a function is completed and will require a new file order checklist is being implemented. Specifically, whenever an annual recertification, interim recertification or change of unit occurs a file order checklist is required and all items on the checklist must be verified. All staff will be trained accordingly. Quality reviews will be conducted for all files to ensure that all required documents are in the files. It is anticipated it will take one year to complete the initial file review. After the initial review files will be selected randomly and reviewed according to an established quality control schedule. Each team will assign a team member to be responsible to collect missing documents identified during a quality control audit. All staff members will be responsible to collect missing information discovered when completing an annual recertification, interim recertification or change of unit. The HAKC has engaged and independent contractor to assist the Deputy Executive Director and Executive Director in overseeing these corrective actions during the next fiscal year.
2018-002
FAC accepted this audit on September 15, 2019 — management decision was due March 15, 2020.
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2017-001
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2017-002
FAC accepted this audit on September 13, 2018 — management decision was due March 13, 2019.
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2016-002
FAC accepted this audit on September 26, 2017 — management decision was due March 26, 2018.
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