Housing Authority of the City of Omaha

HVC Eligibility 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: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) 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). (3) 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). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (6) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516).HVC Eligibility 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: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) 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). (3) 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). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (6) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Condition: Out of 40 tenant files tested for eligibility, 11 tenant files contained errors or were missing required documentation. Questioned costs: $25,596 Context: During the testing of 40 tenant files for eligibility, the following exceptions were noted: - 4 instances where there was not any income support in the tenant file or the income listed on the HUD-50058 was different than the income documentation in the tenant file - 5 instances where the HAP calculation was incorrectly calculated due to incorrect inputs on the HUD-50058 - 5 instances where the recertification of the HUD-50058 was not performed annually - 1 instance where the Authority was unable to locate the HUD-9886 general release form Cause: The Authority failed to implement the internal controls designed to ensure compliance with eligibility requirements were met. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements determined by HUD. Errors in eligibility could result in incorrect HAP payments. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend the Authority: - Review and revise its eligibility determination procedures to ensure full compliance with HUD regulations. - Train staff on proper documentation and verification protocols for income, citizenship/immigration status, Social Security numbers, and student eligibility. - Conduct a file audit to identify and correct any improperly admitted tenants. - Update its Administrative Plan to reflect accurate eligibility screening procedures. Views of responsible officials: There is no disagreement with the audit finding.

U.S. Department of Housing and Urban Development 2024-002 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 - Eligibility Recommendation: We recommend the Authority: - Review and revise its eligibility determination procedures to ensure full compliance with HUD regulations. - Train staff on proper documentation and verification protocols for tenant income, assets, expenses and overall eligibility. - Conduct a file audit to identify and correct any improperly admitted tenants. - Update its Administrative Plan to reflect accurate eligibility screening procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. Additional Quality Control personnel have been added in 2025 to review files and confirm calculations. Electronic workflow processes are also being implemented to track regulatory compliance and flag files when not all required processes are completed. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

2023-002

HVC Reasonable Rent 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: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. 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: Out of 25 tenant files tested for rent reasonableness, 2 tenant files contained exceptions. Questioned costs: $4,416 Context: During the testing of 25 tenant files for rent reasonableness, there were 2 instances where the contract rent per the HUD-50058 was greater than the approved rent per the rent determination form. Cause: The Authority failed to implement internal controls designed to ensure the proper reasonable rent is used on the HUD-50058. Effect: The Authority is not in compliance with federal regulations regarding reasonable rent requirements determined by HUD. Repeat Finding: No Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Views of responsible officials: There is no disagreement with the audit finding.

U.S. Department of Housing and Urban Development 2024-004 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Rent Reasonableness Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. Increased effort with quality control and staff training will be focused in this area to ensure the HUD-50058 and rent determinations match and are clear on the comparable units. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

HVC HQS Inspections 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: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: Out of 40 tenant files tested for annual HQS inspections, 6 tenant files contained exceptions. Questioned costs: None Context: During the testing of 40 tenant files for annual HQS inspections, there were 6 instances where the unit was not inspected on an annual basis Cause: The Authority failed to implement internal controls designed to ensure the units are inspected annually. Effect: The Authority is not in compliance with federal regulations regarding HQS inspection requirements determined by HUD. Repeat Finding: No Recommendation: We recommend the Authority implement controls to ensure that all units are inspected annually. We recommend the Authority hire an outside firm to perform inspections if there is not capacity internally. Views of responsible officials: There is no disagreement with the audit finding.

U.S. Department of Housing and Urban Development 2024-005 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Annual HQS Inspections Recommendation: We recommend the Authority implement controls to ensure that all units are inspected annually. We recommend the Authority hire an outside firm to perform inspections if there is not capacity internally. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. The Authority has identified an error whereby our data system isn’t identifying every unit due for an annual inspection. The Authority is implementing a new procedure to confirm every household due for an annual recertification is also pulling for an annual inspection. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Ashley Hatheway, CFO at (402) 444-6900.

Federal Program Titles: Section 8 Housing Choice Vouchers Program, Federal Catalog Numbers: 14.871 Noncompliance - E - Eligibility Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of forty-three (43) tenant files, the following information was unavailable for examination at the time of audit: Verification of Income Verification of Assets (1)HUD Form 50058. Our sample size is statistically valid. Known Questioned Costs: 7,162 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Voucher Program is in non-compliance with the eligibility type of compliance requirements of the program. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis.

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program, Federal Catalog Numbers: 14.871 Noncompliance - E - Eligibility Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of forty-three (43) tenant files, the following information was unavailable for examination at the time of audit: (3) Verification of Income (2) Verification of Assets HUD Form 50058 Our sample size is statistically valid. Known Questioned Costs: 7,162 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Voucher Program is in non-compliance with the eligibility type of compliance requirements of the program. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Philisa Smith, HCV Director, is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring by December 31, 2024.

2022-002

Finding 2023-003: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Enforcement. For units under a HAP contract that fail to meet HQS, the PHA must require the owner to correct all life threatening HQS deficiencies within 24 hours after the inspections and all other deficiencies within 30 days or within a specified PHA-approved extension. Condition: Based upon inspection of the Authority’s files and on discussion with management, the Authority did not properly abate one (1) out of twenty-five (25) annual failed inspections selected for testing. Context: The Authority did not properly abate one (1) out of twenty-five (25) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Known Questioned Costs: $1,532 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS enforcement. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis.

Finding 2023-003: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Enforcement. For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct all life threatening HQS deficiencies within 24 hours after the inspections and all other deficiencies within 30 days or within a specified PHA-approved extension. Condition: Based upon inspection of the Authority’s files and on discussion with management, the Authority did not properly abate one (1) out of twenty-five (25) annual failed inspections selected for testing. Context: The Authority did not properly abate one (1) out of twenty-five (25) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Known Questioned Costs: $1,532 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS enforcement. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Philisa Smith, HCV Director, is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring by December 31, 2024.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program, Federal Catalog Numbers: 14.871 Material Noncompliance Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of forty-five (45) tenant files, the following information was unavailable for examination at the time of audit: (2) Lead Based Paint forms (1) Original Application (2) Verification of Income (1) Verification of Assets (1) Annual HQS Inspection form (1) HUD Form 9887 Consent to Release Information (1) HUD Form 50058. Our sample size is statistically valid. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Voucher Program is in material non-compliance with the eligibility type of compliance requirements of the program. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis.

Finding Reference Number: 2022-001 Recommendation The Authority should ensure proper internal controls, which include timely monthly reconciliations of account balances, are in place to prevent material weaknesses from occurring. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for implementing the corrective action plan. Completion date or proposed completion date: December 31, 2023 Action(s) taken or planned on the finding Gary Hatfield is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring. Finding Reference Number: 2022-002 Recommendation We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Reporting views of responsible officials The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Chief Financial Officer who will implement the required safeguards and ensure that the Authority follows its Section 8 Administrative Plan and the HUD compliance requirements to remedy the aforementioned deficiencies. Completion date or proposed completion date: December 31, 2023 Action(s) taken or planned on the finding Gary Hatfield is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring.

2021-002