EIN: 520859090
UEI: SGKBY3QJSCY5
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 4, 2026. 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 September 4, 2026 (12 days from today).
What is a management decision? →During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $ 16,814 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following in 4 files: - 2 files where abatement ought to have been implemented, but records could not be located. - 3 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: - 25 instances where the annual inspection was not performed in a timely manner and the Commission failed to enforce the regulations. Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abatement of housing assistance payments are being followed. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/24-6/30/25) Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Material Weakness in Internal Control over Compliance. - Material Noncompliance (Modified Opinion) Criteria: PHA 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 PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). 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: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $ 16,814 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following in 4 files: - 2 files where abatement ought to have been implemented, but records could not be located. - 3 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: - 25 instances where the annual inspection was not performed in a timely manner and the Commission failed to enforce the regulations. Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abatement of housing assistance payments are being followed. View of Responsible Officials: There is no disagreement with the audit finding.
HCVP Housing Quality Standards and Enforcement Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abatement of housing assistance payments are being followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC will collaborate with the software vendor, IT department, and a third-party consultant to remediate system deficiencies affecting inspection tracking and compliance. This will include developing and implementing quality control reports to identify units with failed or overdue inspections, restoring accurate inspection date tracking, and strengthening monitoring processes to ensure timely inspections, abatements, and enforcement in accordance with program regulations. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division. Planned completion date for corrective action plan: HRD has initiated implementation of the corrective action plan by engaging the IT department and the software vendor to assess system deficiencies impacting inspection tracking, abatement enforcement, and regulatory compliance. Initial meetings have focused on identifying root causes, reviewing data integrity issues, and evaluating potential system enhancements and reporting solutions to improve monitoring and oversight. HOC will continue coordinated efforts with IT, the software vendor, and a third-party consultant to design, test, and implement corrective measures. Full implementation and stabilization of the identified solutions is anticipated to be completed by December 2026.
2024-001
During our testing, we noted the Commission did not consistently use internal controls to ensure that eligibility requirements were being met. Questioned Costs: $ 13,635 Context: Testing of 60 tenant files for eligibility revealed that 1 file had the following exception: - 1 file that was missing support needed to substantiate the asset total per HUD-50058/HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴PBRA/MOD Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/24-6/30/25) Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance. - Other Matters Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not consistently use internal controls to ensure that eligibility requirements were being met. Questioned Costs: $ 13,635 Context: Testing of 60 tenant files for eligibility revealed that 1 file had the following exception: - 1 file that was missing support needed to substantiate the asset total per HUD-50058/HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.
PBRA/MOD Eligibility Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, will retrain all site staff on acceptable and complete forms of income, asset, and expense documentation for initial certifications and the annual recertification process no later than February 15, 2026. Pratum's Compliance team will continue to review each new move-in file from eligibility determination through lease execution to ensure ongoing programmatic compliance. In addition, the Compliance team will complete supplemental training by February 15, 2026, to reinforce proper use of the internal control's checklist, which is required to be attached to all submitted move-in files. Name(s) of the contact person(s) responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action outlined above.
2024-003
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: $ 75,780 Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: - 23 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period - 2 files were missing the Housing Specialist signoff on the inspection completed. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. View of Responsible Officials: There is no disagreement with the audit finding
Show full finding ▾Hide full finding ▴PBRA/MOD Housing Quality StandardsFederal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/24 - 6/30/25) Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Material Weakness in Internal Control over Compliance. - Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: $ 75,780 Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: - 23 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period - 2 files were missing the Housing Specialist signoff on the inspection completed. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. View of Responsible Officials: There is no disagreement with the audit finding
PBRA/MOD Housing Quality Standards Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, policy has been updated to reflect the requirement to complete within 365 days of the previous inspection. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action as outlined above.
2024-004
During our testing, we noted the Authority did not have adequate internal controls designed to ensure that vacancies were appropriately accounted for in HUD-52670 forms, and that HAP activity in the HAP registers correctly reflected the vacancies. Questioned Costs: $ 352 Context: Testing of 8 files resulted in exceptions in 1 file: - 1 case in which the HAP activity recorded to the HAP registers did not match with the timespan of the tenant vacancy observed in separate documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and other relevant records. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴PBRA/MOD – Vacant Units Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.857 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/24 - 6/30/25) Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance. - Other Matters Criteria: The PHA or owner must reduce claims for assistance on vacant units under certain circumstances. However, there are instances where special claims are allowed for vacancy losses, unpaid rent, and tenant damages on eligible units (24 CFR sections 880.611, 881.601, 882.411, 882.808(f), 883.701, 884.106, 886.109, and 886.309). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that vacancies were appropriately accounted for in HUD-52670 forms, and that HAP activity in the HAP registers correctly reflected the vacancies. Questioned Costs: $ 352 Context: Testing of 8 files resulted in exceptions in 1 file: - 1 case in which the HAP activity recorded to the HAP registers did not match with the timespan of the tenant vacancy observed in separate documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and other relevant records. View of Responsible Officials: There is no disagreement with the audit finding.
PBRA/MOD Vacant Units Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and within other relevant records. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies site staff will retrain staff on the move-out / deposit accounting process and the required month end closeout process no later than February 28, 2026. Regional Managers will review and confirm completion of end-of-month checklists to verify that all required monthly tasks have been performed, thereby reducing the risk of this exception occurring in the future. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately corrected this discrepancy and will implement the remaining corrections by February 28, 2026.
FAC accepted this audit on December 19, 2024 — management decision was due June 19, 2025.
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 001 – HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA 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 PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). 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: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Housing Opportunities Commission (“HOC”) and Yardi, software vendor, recently identified a glitch in the system that led to the omission of several inspections. HOC met with Yardi to resolve this issue and autocorrect excluded units. HOC will generate new reports that will accurately identify all residents requiring inspections within 12 months of their last inspection. Effective immediately, staff will generate and review a monthly report of abatements to cancel any HAP contracts that have been in abatement for more than 30 days and assist clients in relocating to another unit. Tenants with units in abatement will receive a 60-day notice of the proposed termination, which will include a relocation packet to initiate the voucher re-issuance process. Staff will hold the termination in abeyance for 30 days if the landlord addresses the cited repairs. Additionally, the Program Manager will conduct a quality control review of 5% of the files for abated units. Both HRD and Gilson, a third party inspection vendor, faced strain due to the high volume of backlogged and current inspections. To mitigate this, the following actions have been implemented: -HRD and Gilson hired additional back-office staff to monitor and manage the workload. -Gilson has cross-trained staff to handle inspection caseloads in the event of staff shortages. -HRD has designated internal staff members to monitor abatements and ensure that re-inspections occur within the required timeframes. These measures aim to improve efficiency and ensure timely processing of inspections. As part of the bi-monthly quality control review, the Compliance team will include an assessment of the abatement report, identifying any units that have been in abatement for over 30 days. The Compliance team will continue to conduct bi-monthly quality control reviews, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division and Darcel Cox, Vice President of Compliance. Planned completion date for corrective action plan: HRD has immediately implemented the corrective actions outlined above. The HOC compliance team will implement the additional abatement review process starting in December 2024.
2023-002
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 002 – HCVP Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: As a condition of admission or continued occupancy, the PHA must 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, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must 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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission 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 sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.
Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective September 2024, the HOC compliance team significantly enhanced the quality control review process to proactively identify SEMAP findings and eligibility discrepancies before the end of each fiscal year. Staff anticipates that this proactive approach will facilitate early identification of training needs on a more frequent basis, ensuring compliance standards are met while also improving overall program effectiveness. Additionally, HRD staff will identify and address systemic findings during monthly staff meetings. To further support these efforts, HOC enlisted a third-party consulting firm to provide training to new and existing staff in October 2024. Staff were trained on eligibility, portability and SEMAP requirements. Additional HOTMA training is scheduled on 11/6/24 - 11/7/24. Moreover, HOC will continue to procure recurring training based on systemic quality control findings prior to the end of the fiscal year. This comprehensive approach will ensure that staff are well-equipped to address any challenges and enhance overall compliance and effectiveness. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division and Darcel Cox, Vice President of Compliance. Planned completion date for corrective action plan: Staff training commenced October 2024 and will continue throughout the fiscal year.
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: $21,838 Context: Testing of 60 tenant files for eligibility revealed that 38 files had the following exceptions: -26 files were missing the application which includes signoff from the program specialist -28 files were missing documentation needed to support and recalculate total income per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the asset total per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the expenses total per HUD-50058/HUD-50059 -3 files where the annual examination was not processed within 12-month regulatory period -34 files that were missing the recertification checklist as part of their internal controls Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 003 – PBRA/MOD Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: $21,838 Context: Testing of 60 tenant files for eligibility revealed that 38 files had the following exceptions: -26 files were missing the application which includes signoff from the program specialist -28 files were missing documentation needed to support and recalculate total income per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the asset total per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the expenses total per HUD-50058/HUD-50059 -3 files where the annual examination was not processed within 12-month regulatory period -34 files that were missing the recertification checklist as part of their internal controls Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.
Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC’s third-party management agent, Pratum Companies, will ensure that all site staff with access to files complete the "Intro to Affordable Housing" training hosted by Pratum Compliance within the next 60 days. Pratum will also mandate that Regional Managers conduct random quarterly reviews of move-in files and annual recertifications. Furthermore, Regional Compliance Managers will perform spot checks and file reviews throughout the year. Currently, every move-in file is reviewed by Pratum’s corporate Compliance team for program compliance, with Community Managers conducting an initial review before submission to the compliance team for final approval. Pratum will ensure that each recertification packet includes a completed application, documentation of income, assets, expenses, and an executed recertification checklist. Additionally, Pratum will generate and send reminder letters at 120, 90, 60, and 30 days to all households to minimize late annual recertifications. The Pratum Regional Managers and the Vice President of Operations will provide oversight and conduct weekly check-ins with the team to assess progress and completion of tasks. Regional Property Managers will review all corrective actions to ensure accuracy. A tracking spreadsheet will be maintained and reviewed during these weekly check-ins. This information will also be shared with the HOC compliance team during the monthly compliance and operations meetings to ensure alignment and transparency. HOC’s Property Management Division now has a Compliance Manager who has updated the internal review process to mandate that all new move-ins and annual recertifications include a completed application, documentation of income, assets, expenses, and an executed recertification checklist. The HOC compliance team will focus on conducting site visits for the Project Based Rental Assisted properties following the same guidelines used for the annual financial audit. The goal is to perform a 100% file review for properties with 25 or less units and a 50% file review for properties with more than 25 units. The Compliance team will continue to conduct bi-monthly quality control reviews for the HOC managed properties, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions outlined above and is committed to correcting all specific discrepancies by March 31, 2025. The HOC compliance team will start the site visits in January 2025 and will review files from the start of the fiscal year. The PM Division has begun the updated internal review process outlined in the corrective action and has committed to correcting the discrepancies by November 30, 2024.
2023-003
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: -40 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period -26 files missing the letters sent to tenants informing them of the scheduled HQS inspections Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 004 – PBRA/MOD Housing Quality Standards Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: -40 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period -26 files missing the letters sent to tenants informing them of the scheduled HQS inspections Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum has implemented a policy requiring annual inspections to align with annual recertifications, ensuring compliance with HUD policies. Pratum Regional Property Managers will verify that all annual inspections and their corresponding forms are completed and properly filed in each resident's file. Additionally, a copy of the completed unit inspection form will be uploaded to Yardi along with the certification acket. Pratum will also ensure that all documentation related to scheduled HQS inspections is filed in the resident file and uploaded to Yardi, along with the completed unit inspection form. HOC’s PM Division has engaged an inspection vendor, Gilson Housing Partners, to conduct all annual inspections for the HOC managed properties. The inspections will begin on December 1, 2024 with PBRA communities being the priority. They will complete approximately 150 inspections per month and utilize Yardi Maintenance IQ for record keeping. The results of each inspection will be entered into the system by Gilson and HOC’s Maintenance and PM will have the responsibility of addressing all work.This partnership will ensure that all inspections are completed on schedule and meet the necessary standards. The Compliance team will continue to conduct bi-monthly quality control reviews for the HOC managed properties, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. HOC’s third party inspections vendor will begin inspecting units no later than December 1, 2024 and perform annual inspections moving forward.
2023-004
During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 4 files had the following exceptions: -2 files failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC -2 instances where the Authority failed to provide the TRACS submission Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 005 – PBRA/MOD - Public Housing Information Center (PIC) & Tenant Rental Assistance Certification (TRACS) Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 4 files had the following exceptions: -2 files failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC -2 instances where the Authority failed to provide the TRACS submission Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.
Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previously,Pratum was responsible for completing the certifications and the HOC team was responsible for transmitting the certifications through TRACS. Effective October 1 2024, Pratum assumed responsibility of ensuring that all certifications are transmitted to TRACS in alignment with the HAP reported date. The Regional Property Manager will conduct monthly reviews of HAP and TRACS submissions to ensure accuracy. HRD staff will provide weekly internal staff training to correct PIC errors and procure additional training from a third party consulting company.. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Lynn Hayes, Vice President of Housing Resources. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HRD team has corrected the errors and will attempt to secure training from a consultant company no later than March 31, 2024.
2023-005
During our testing, we noted the Commission did not have adequate internal controls designed to ensure rent changes were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 12 exceptions: - 12 files where the rent on the 50059 did not match the approved rent schedules Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over rent changes. Effect: The Commission is not in compliance with program requirements over rent changes. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 006 – PBRA/MOD – Contract Rent Change Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner applies or ensures annual adjustments to contract rents are applied. The HAP original term contract or renewal contract specifies the method to be used to determine rent adjustments. Adjustments must not result in material differences between rents charged for assisted units and comparable unassisted units except as those differences existed at contract execution. Special adjustments to contract rents, within the original contract term, may also be made to the extent deemed necessary by the PHA or HUD (24 CFR sections 880.609, 881.601, 882.410, 882.808(e), 883.701, 884.109, 886.112, 886.312(c) and Section 524 of Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) Title V of the HUD Fiscal Year 1998 Appropriations Act, Pub. L. 105-65, as amended). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure rent changes were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 12 exceptions: - 12 files where the rent on the 50059 did not match the approved rent schedules Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over rent changes. Effect: The Commission is not in compliance with program requirements over rent changes. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.
Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct contract rent is reflected on the hUD50059. Moving forward management will ensure that site staff review the HUD-50059 contract rent amounts for accuracy against the approved Rent Schedule. Additionally, Pratum will ensure that certifications are completed early, ahead of any Gross Rent Increase, and that affected certifications are corrected as needed to reflect the correct contract rents on the HUD-500-59. Pratum will also ensure that rent change letters are provided as required, with a copy retained in the resident file along with the certification. Furthermore, management will ensure that a copy of the rent change letter is uploaded to Yardi, along with the completed certification, the completed unit inspection form, and the notification letters for HQS annual inspection scheduling. Lastly, Pratum will review the reference tenant file and provide a copy of the HUD-50059 and rent change form for review. Management will ensure that these documents are retained in the resident file and uploaded to Yardi upon completion of all further certifications. The HOC compliance team will focus on conducting site visits for the Project Based Rental Assisted properties following the same guidelines used for the annual financial audit. The goal is to perform a 100% file review for properties with 25 or less units and a 50% file review for properties with more than 25 units. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HOC compliance team will start site visits by January 2025 and will review files from the start of the fiscal year.
During our testing, we noted the Commission did not have adequate internal controls designed to ensure utility allowances were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 6 exceptions: 6 files where the utility allowance on the 50058/50059 did not match the approved utility allowance Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over utility allowances. Effect: The Commission is not in compliance with program requirements over utility allowances. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 007 – PBRA/MOD – Utility Allowances Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner must (a) establish or ensure tenant utility allowances based on utility consumption and rate data for various sized units, structure types, and fuel types, (b) make an annual review of tenant utility allowances to determine their reasonableness, and (c) adjust the allowances, when appropriate (24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure utility allowances were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 6 exceptions: 6 files where the utility allowance on the 50058/50059 did not match the approved utility allowance Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over utility allowances. Effect: The Commission is not in compliance with program requirements over utility allowances. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.
Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct utility allowance is reflected on the HUD-50059. Management will also ensure that, going forward, site staff review the HUD-50059 utility allowance amounts for accuracy against the approved rent schedule. Additionally, Pratum will ensure that any certifications completed in advance of the Gross Rent Increase are corrected as needed to accurately reflect the correct utility allowance on the HUD-50059. HRD will review and update utility allowances currently in use, comparing them against the latest HUD-approved MOD Rehabilitation gross rent schedule. HRD and HOC Compliance team will develop or update policies and procedures to ensure that utility allowances are verified and updated as required by HUD. The training manager will conduct training sessions for relevant staff members on the utility allowance requirements and how to update them in HRD’s system of record database. As a preventive action, HRD’s management will establish a quarterly file review procedure to ensure that the utility allowances align with the HUD utility allowance approval. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC, Ali Ozair, Vice President of Property Management with HOC and Lynn Hayes, Vice President of Housing Resources Division with HOC. Planned completion date for corrective action plan: Pratum has immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. HRD has immediately implemented and will have the corrections to the impacted and future files completed by December 31, 2024.
During our testing, we noted the Commission did not have adequate internal controls designed to ensure claims for assistance were terminated. Questioned costs: $15,963 Context: Testing of 11 tenant files revealed the following 2 exceptions: - 2 files where claims for assistance were not properly terminated Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 008 – PBRA/MOD – Vacant Units Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: The PHA or owner must reduce claims for assistance on vacant units under certain circumstances. However, there are instances where special claims are allowed for vacancy losses, unpaid rent, and tenant damages on eligible units (24 CFR sections 880.611, 881.601, 882.411, 882.808(f), 883.701, 884.106, 886.109, and 886.309). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure claims for assistance were terminated. Questioned costs: $15,963 Context: Testing of 11 tenant files revealed the following 2 exceptions: - 2 files where claims for assistance were not properly terminated Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. View of Responsible Officials: There is no disagreement with the audit finding.
Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will ensure that move-outs are processed promptly to prevent assistance payments from being requested for vacant units. The Regional Property Manager will oversee the completion and review of end-of-month checklists to confirm that all monthly tasks have been addressed, thereby minimizing the likelihood of this exception occuring in the future. Effective immediately, HOC’s PM Compliance Manager will ensure that move-outs are processed in a timely manner and will review monthly reports to confirm that esident terminations are handled accurately. For both HOC and Pratum, the HOC team will incorporate any open move-out and move-in actions into the monthly review of past-due certifications as part of the report. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum and HOC have immediately implemented the corrective actions as outlined above. Both discrepancies have been resolved. The HOC team will include open move-in and move-out actions within the report effective November 2024. If the U.S. Department of Housing and Urban Development has questions regarding this schedule, please call Timothy Goetzinger, Senior Vice President, Finance / Chief Financial Officer at (301) 949-4690.
FAC accepted this audit on December 14, 2023 — management decision was due June 14, 2024.
During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View 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 Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance. Other Matters. Criteria or specific requirement: The PHA is required to submit the HUD-50058 (Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.
Recommendation: The Commission should implement processes to ensure that all fatal errors are corrected in the PIC system in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Submission was delayed as a result of another PHA failing to complete a “port out” action PIC. HOC could not complete the “port in” action and received a delayed response from the initial PHA. Effective December 2023, a procedure of weekly monitoring will be implemented to curtail PIC fatal errors. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President/Housing Resources Planned completion date for corrective action plan: Effective Immediately, Ongoing.
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View 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 Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance. Other Matters. Criteria: PHA 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 PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). 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: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC has hired a new Inspections contractor, Gilson Housing Partners, to conduct all inspections effective October 1, 2023. Gilson Housing Partners will send HOC detailed weekly reports of all inspection activity, including failed units, units requiring abatement, scheduled/rescheduled inspections, and quality control reports. HOC will monitor these reports to ensure they meet program requirements. Gilson will also meet with HOC staff monthly to discuss progress and program operations. Designated staff members will be assigned to place/remove units in abatement. Bi-monthly, the HOC Compliance Team conducts quality control reviews of completed actions. Following completion, staff from the Housing Resources Management, Inspections and HOC Compliance Teams meet to discuss systemic findings and schedule staff training in areas requiring improvement. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President/Housing Resources Planned completion date for corrective action plan: October 2023
2022-003
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed the following exceptions: - 1 file missing documentation needed to support and recalculate total income per HUD-50059 - 2 files that were missing support needed to substantiate the asset total per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View 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 Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance. Other Matters. Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed the following exceptions: - 1 file missing documentation needed to support and recalculate total income per HUD-50059 - 2 files that were missing support needed to substantiate the asset total per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.
Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOCs third party management agent, Edgewood Management, Regional Managers will review move in files and annual recertifications during monthly inspections of the property. In addition, Edgewood will ensure that the Regional Compliance Managers are spot checking and reviewing files throughout the year. The HOC compliance team will continue to monitor as part of the site inspections. Name(s) of the contact person(s) responsible for corrective action: Darcel Cox, Vice President/Compliance Planned completion date for corrective action plan: Effective Immediately, Ongoing.
2022-004
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following exceptions: - 4 files did not have an annual inspection that was completed within the 12-month fiscal period. - 33 files did not have a previous or subsequent inspection performed to verify the Commission is performing inspection on an annual basis. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View 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 Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance. Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following exceptions: - 4 files did not have an annual inspection that was completed within the 12-month fiscal period. - 33 files did not have a previous or subsequent inspection performed to verify the Commission is performing inspection on an annual basis. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC’s third party management agent, Edgewood, will complete inspections in alignment with the annual recertifications. The Edgewood Regional Managers will confirm that inspections are complete and the inspection will be uploaded with the certification. The HOC compliance team will continue to monitor as part of the Quality Control Site Visits. Name(s) of the contact person(s) responsible for corrective action: Darcel Cox, Vice President/Compliance Planned completion date for corrective action plan: Effective Immediately, Ongoing.
During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 2 files had the following exceptions: - 1 file failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC. - Management failed to follow up on 1 file due to TRACS creating a termination for late processing of reexamination. Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View 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 Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance. Other Matters. Criteria: The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 2 files had the following exceptions: - 1 file failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC. - Management failed to follow up on 1 file due to TRACS creating a termination for late processing of reexamination. Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.
Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Edgewood Management Regional Managers will review monthly TRACs reports to ensure TRACs errors are addressed immediately. The HOC Compliance Team will monitor the Secure Portal monthly and follow up with the Edgewood team for any fatal errors not addressed. Name(s) of the contact person(s) responsible for corrective action: Darcel Cox, Vice President/Compliance Planned completion date for corrective action plan: Effective Immediately, Ongoing.
During our testing, we noted the Commission did not have adequate internal controls designed to ensure tenant permanent files contain waiting list documents. As a result, the Commission is unable to support the admission of the tenant in accordance with the admission policies. Questioned costs: Unknown Context: Testing of 6 tenant files for waiting list documentation revealed that: - 1 selection could not be supported by documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over new admissions to the program. Effect: The Commission is not in compliance with program requirements over the waiting list. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. View 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 Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance. Other Matters. Criteria: PHA must select participants from the waiting list in accordance with the admission policies in its administrative plan and maintain documentation which shows that, at the time of admission, the family actually met the preference criteria that determined the family’s place on the waiting list. For the Mod Rehab SRO program, eligible individuals may be referred to the PHA for eligibility determination as a result of the owner’s/sponsor’s outreach or through the PHA waiting list (24 CFR sections 880.603, 881.601, 882.514, 882.808(b)(2), 883.701, 884.214, and 886 subparts A and C). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure tenant permanent files contain waiting list documents. As a result, the Commission is unable to support the admission of the tenant in accordance with the admission policies. Questioned costs: Unknown Context: Testing of 6 tenant files for waiting list documentation revealed that: - 1 selection could not be supported by documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over new admissions to the program. Effect: The Commission is not in compliance with program requirements over the waiting list. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. View of Responsible Officials: There is no disagreement with the audit finding.
Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new procedure will be implemented immediately requiring staff to upload a printed copy of the electronic wait list application along with the move in file. The Edgewood compliance team to verify that the applicant was selected from the waitlist prior to move-in approval. Name(s) of the contact person(s) responsible for corrective action: Darcel Cox, Vice President/Compliance Planned completion date for corrective action plan: Effective Immediately, Ongoing.
FAC accepted this audit on January 16, 2023 — management decision was due July 16, 2023.
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View 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 Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/21-6/30/22) Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance. ? Other Matters. Criteria: As a condition of admission or continued occupancy, the PHA must 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, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must 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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission 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 sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.
2022-001 Housing Voucher Cluster-HCVP Eligibility ? Assistance Listing No. 14.871 / 14.879 Context: Testing of 40 HCVP tenant files for eligibility standards revealed the following: ? One file where the tenant received an allowance without proper verification or support. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? The Housing Resources Division(HRD) will hire an internal trainer to address systemic errors, reinforce program rules and introduce new regulatory requirements. The trainer will meet with staff monthly to reinforce program requirements and provide individual coaching as needed. Moreover, HOC will continue to archive recorded trainings in a resource library so the materials are accessible to staff at all times ? The HOC Compliance Team will conduct quality control reviews of completed files. Staff from the Housing Resources Management Team will meet with the HOC Compliance Team following each review period to discuss systemic findings and schedule staff trainings in areas requiring improvement. ? HOC will procure a professional consulting company to provide a comprehensive refresher training on the Housing Choice Voucher (HCV) eligibility requirements. ? The Housing Resources Management Team will continue to meet with staff regularly to provide staff development trainings, including reiteration of the Quality Control Checklist, the HUD verification hierarchy and uploading all documents into AO Docs, HOCs electronic filing system. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Director of Housing Resources/Darcel Cox, Chief Compliance Officer Planned completion date for corrective action plan: June 30,, 2023
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that rent reasonableness requirements were being met. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for rent reasonableness standards revealed the following: 1 file that was missing the rent reasonableness comparison report to substantiate the contract rent. 1 file that was missing the lease amendment letter effective for the sampled contract rent change. Rent reasonableness comparison report was performed late, after the rent effective date. Cause: The Commission does not have controls in place to ensure it is meeting rent reasonableness requirements set by HUD. Effect: The Commission is not in compliance with program requirements over rent determination. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the rent approval process for every tenant. View 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 Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/21-6/30/22) Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance. ? Other Matters. Criteria: As a condition of admission or continued occupancy, 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 5 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: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that rent reasonableness requirements were being met. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for rent reasonableness standards revealed the following: 1 file that was missing the rent reasonableness comparison report to substantiate the contract rent. 1 file that was missing the lease amendment letter effective for the sampled contract rent change. Rent reasonableness comparison report was performed late, after the rent effective date. Cause: The Commission does not have controls in place to ensure it is meeting rent reasonableness requirements set by HUD. Effect: The Commission is not in compliance with program requirements over rent determination. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the rent approval process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.
2022-002 Housing Voucher Cluster-HCVP Rent Reasonableness Test ? Assistance Listing No. 14.871 / 14.879 Context: Testing of 40 HCVP tenant files for rent reasonableness standards revealed the following: ? One file that was missing the rent reasonableness comparison report to substantiate the contract rent. ? One file that was missing the lease amendment letter effective for the sampled contract rent change. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the rent approval process for every tenant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? HOC will continue to work with the software developer to identify and resolve software glitches. ? The HOC Compliance Team will conduct quality control reviews of completed files. Staff from the Housing Resources Management Team will meet with the HOC Compliance Team following each review period to discuss systemic findings and schedule staff trainings in areas requiring improvement. ? HOC implemented Rent Cafe, Yardi?s software module to process electronic recertifications. The Lease Amendment Letter is automatically uploaded into Yardi when a customer completes the recertification online. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Director of Housing Resources/Darcel Cox, Chief Compliance Officer Planned completion date for corrective action plan: June 30, 2023
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 3 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 3 files where the inspection was not completed and passed within HUD?s granted extension period for COVID 19. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View 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 Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/21-6/30/22) Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance. ? Other Matters. Criteria: PHA 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 PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). 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: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 3 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 3 files where the inspection was not completed and passed within HUD?s granted extension period for COVID 19. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
2022-003 Housing Voucher Cluster-HCVP Housing Quality Standards and Enforcement ? Assistance Listing No. 14.871 / 14.879 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: ? Three files where abatement ought to have been implemented, but records could not be located. Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following: ? Three files where the inspection was not completed annually or within HUD?s granted extension for COVID 19. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? HOC procured Inspection Experts Inc. (?IEI?) on July 1, 2022, to conduct all initial, annual, special and quality control inspections ? HOC meets with IEI monthly to provide the report of annual inspections, and discuss progress and the alignment of expectations. ? HOC staff receives a report of units requiring abatement daily from IEI & immediately place the units in abatement. ? An HOC Senior Manager reviews the abatement report weekly to conduct quality control reviews of all records, ensuring that all units are placed in abatement ? The HOC Compliance Team will conduct quality control reviews of completed files. Staff from the Housing Resources Management Team will meet with the HOC Compliance Team following each review period to discuss systemic findings and schedule staff trainings in areas requiring improvement. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Director of Housing Resources/Darcel Cox, Chief Compliance Officer Planned completion date for corrective action plan: June 30, 2023
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed that 34 files had the following exceptions: - 9 files missing documentation needed to support and recalculate total income per HUD-50059 - 8 files that were missing support needed to substantiate the asset total per HUD-50059 - 7 files that were missing support needed to substantiate the expense total per HUD-50059 - 25 files missing documentation supporting that the tenant was selected from the waitlist in accordance with the Commission?s Administration Plan. - 28 files did not have a certification checklist, or an alternative document, reflecting an HCVP Employee?s signoff on the application or file being completed to document an internal control. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View 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 Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/21-6/30/22) Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance. ? Material Noncompliance (Modified Opinion) Criteria: As a condition of admission or continue occupancy, PHA?s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c)documenting inspections and tenant certifications, as appropriate; and, (d)determining that tenant income did not exceed the maximum limit set by HUD for the PHA?s jurisdiction, as shown in HUD?s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). The PHA must also select participants from the waiting list in accordance with the admission policies in its administrative plan and maintain documentation which shows that, at the time of admission, the family actually met the preference criteria that determined the family?s place on the waiting list. For the Mod Rehab SRO program, eligible individuals may be referred to the PHA for eligibility determination as a result of the owner?s/sponsor?s outreach or through the PHA waiting list (24 CFR sections 880.603, 881.601, 882.514, 882.808(b)(2), 883.701, 884.214, and 886 subparts A and C). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed that 34 files had the following exceptions: - 9 files missing documentation needed to support and recalculate total income per HUD-50059 - 8 files that were missing support needed to substantiate the asset total per HUD-50059 - 7 files that were missing support needed to substantiate the expense total per HUD-50059 - 25 files missing documentation supporting that the tenant was selected from the waitlist in accordance with the Commission?s Administration Plan. - 28 files did not have a certification checklist, or an alternative document, reflecting an HCVP Employee?s signoff on the application or file being completed to document an internal control. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.
2022-004 Section 8 Project Based Cluster-PBRA/MOD Eligibility ? Assistance Listing No. 14.195 / 14.856 Context: Testing of 40 tenant files for eligibility standards revealed that 34 files had the following exceptions: ? Nine files missing documentation needed to support and recalculate total income per HUD-50059. ? Eight files that were missing support needed to substantiate the asset total per HUD-50059. ? Seven files that were missing support needed to substantiate the expense total per HUD-50059. ? 25 files missing documentation supporting that the tenant was selected from the waitlist in accordance with the Commission?s Administration Plan. ? 28 files did not have a certification checklist, or an alternative document, reflecting an HCVP Employee?s signoff on the application or file being completed to document an internal control. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? HOC will procure a third party reviewing to complete a 100% audit of the Project Based Rental Assistance program across all properties. ? Property Management will implement new procedures to ensure that all resident documents are properly maintained. The updated procedures will require that all staff completing recertifications utilize a checklist to ensure that all required documents are obtained and that each document is scanned as attachments directly into HOC?s Yardi system. ? Managers will perform quality control reviews to ensure that procedures are followed and that documents are scanned into the system for all recertifications completed. ? The Regional Manager will review reports monthly to enable confirmation of scanned documents for proper file maintenance. ? The HOC Compliance Team will conduct quality control reviews of completed files. Staff from the Property Management Team will meet with the HOC Compliance Team following each review period to discuss systemic findings and schedule staff trainings in areas requiring improvement. ? The HOC Compliance Team will offer a refresher Housing Path Waitlist training to existing staff and perform monthly quality control reviews to ensure that procedures are followed. ? HOC will procure a professional consulting company to provide a comprehensive refresher training on the Project Based Rental Assistance eligibility requirements. Name(s) of the contact person(s) responsible for corrective action: Ellen Goff, Acting Director of Property Management/Darcel Cox, Chief Compliance Officer Planned completion date for corrective action plan: June 30, 2023
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed that 37 files had the following exceptions: - 22 files did not have an annual inspection completed during or subsequent to the fiscal year - 15 files did not have an annual inspection that was completed within the 12-month fiscal period. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View 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 Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/21-6/30/22) Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance. ? Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed that 37 files had the following exceptions: - 22 files did not have an annual inspection completed during or subsequent to the fiscal year - 15 files did not have an annual inspection that was completed within the 12-month fiscal period. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.
2022-005 Section 8 Project Based Cluster-PBRA/MOD Housing Quality Standards ? Assistance Listing No. 14.195 / 14.856 Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following: ? 22 files did not have an annual inspection completed during or subsequent to the fiscal year. ? 15 files did not have an annual inspection that was completed within the 12-month fiscal period. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? Property Management staff will be retrained on the unit inspection requirements to ensure that all inspections are documented and the that the completed executed signed inspection forms are scanned into the resident?s record in HOC?s Yardi system. ? Managers will review these actions and provide greater oversight to ensure that move-in and move-out inspections are performed for every unit upon lease signing and when residents vacate a unit. ? The Property Management and Maintenance Divisions will develop an annual inspection schedule ? The HOC Compliance Team will review inspections as part of the quality control review. Name(s) of the contact person(s) responsible for corrective action: Ellen Goff, Acting Director of Property Management/Darcel Cox, Chief Compliance Officer Planned completion date for corrective action plan: June 30, 2023
During our testing, we noted the Commission did not have adequate internal controls designed to ensure that tenant utility allowances were properly calculated. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed that 1 file had the following exception: - 1 recertification displayed a tenant utility allowance that did not match the value listed in HUD Form-52667 effective for the period tested. Cause: The Commission does not have controls in place to ensure it is meeting tenant utility allowance requirements set by HUD. Effect: The Commission is not in compliance with program requirements over tenant utility allowances. Repeat Finding: Not a repeat. Recommendation: The Commission should review the procedures taken by Section 8 Cluster employees to ensure that they correctly add utility allowance values from HUD Form-52667 to newly processed certifications. All Section 8 cluster employees should be trained on any changes made to the these procedures. View 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 Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/21-6/30/22) Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiencies in Internal Control over Compliance. ? Other Matters Criteria: The PHA or owner must (a) establish or ensure tenant utility allowances based on utility consumption and rate data for various sized units, structure types, and fuel types, (b) make an annual review of tenant utility allowances to determine their reasonableness, and (c) adjust the allowances, when appropriate (24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that tenant utility allowances were properly calculated. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed that 1 file had the following exception: - 1 recertification displayed a tenant utility allowance that did not match the value listed in HUD Form-52667 effective for the period tested. Cause: The Commission does not have controls in place to ensure it is meeting tenant utility allowance requirements set by HUD. Effect: The Commission is not in compliance with program requirements over tenant utility allowances. Repeat Finding: Not a repeat. Recommendation: The Commission should review the procedures taken by Section 8 Cluster employees to ensure that they correctly add utility allowance values from HUD Form-52667 to newly processed certifications. All Section 8 cluster employees should be trained on any changes made to the these procedures. View of Responsible Officials: There is no disagreement with the audit finding.
2022-006 Section 8 Project Based Cluster-PBRA/MOD Tenant Utility Allowances ? Assistance Listing No. 14.195 / 14.856 Context: Testing of 40 tenant files for eligibility standards revealed the following: ? One recertification displayed a tenant utility allowance that did not match the value listed in HUD Form-52667 effective for the period tested. Recommendation: The Commission should review the procedures taken by Section 8 Cluster employees to ensure that they correctly add utility allowance values from HUD Form-52667 to newly processed certifications. All Section 8 cluster employees should be trained on any changes made to these procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? HRD will hire an internal trainer to address systemic errors, reinforce program rules and introduce new regulatory requirements. The trainer will meet with staff monthly to reinforce program requirements and provide individual coaching as needed. Moreover, HOC will continue to archive recorded trainings in a resource library so the materials are accessible to staff at all times ? The HOC Compliance Team will conduct quality control reviews of completed files. Staff from the Property Management Team will meet with the HOC Compliance Team following each review period to discuss systemic findings and schedule staff trainings in areas requiring improvement. ? HOC will procure a professional consulting company to provide a comprehensive refresher training on the HCV eligibility requirements Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Director of Housing Resources/Darcel Cox, Chief Compliance Officer Planned completion date for corrective action plan: June 30, 2023
FAC accepted this audit on December 8, 2020 — management decision was due June 8, 2021.
During our testing, we noted that the Commission?s internal controls did not always ensure that tenant files included all required documentation. Questioned costs: $24,000. Context: During our testing of 40 tenant files, 1 recertification packet could not be located. The sample was a statistically valid sample. Cause: The Commission did not follow established procedures as documented in its HCVP Administrative Plan to ensure that tenant files included all required documentation and that income and assets were properly calculated. Effect: The Commission did not obtain all required documentation and releases at the time of recertification to support housing assistance payment calculations. The Commission may have made incorrect payments to landlords. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2019-001. Recommendation: We recommend the Commission review the checklists used by housing specialists when they complete an annual recertification to ensure the checklist adequately identifies all information required. We also recommend management identify the specialists responsible for the erroneous files and investigate whether findings represent a systemic problem or are limited to a few specialists. Additional training for housing specialists would also improve accuracy. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster CFDA Number: 14.871/14.879 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance, Compliance Criteria or specific requirement: 24 CFR 982.516 requires the PHA to annually obtain and document in the family file the third-party verification of reported family annual income. As a condition of admission or continued occupancy, the PHA must 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). Condition: During our testing, we noted that the Commission?s internal controls did not always ensure that tenant files included all required documentation. Questioned costs: $24,000. Context: During our testing of 40 tenant files, 1 recertification packet could not be located. The sample was a statistically valid sample. Cause: The Commission did not follow established procedures as documented in its HCVP Administrative Plan to ensure that tenant files included all required documentation and that income and assets were properly calculated. Effect: The Commission did not obtain all required documentation and releases at the time of recertification to support housing assistance payment calculations. The Commission may have made incorrect payments to landlords. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2019-001. Recommendation: We recommend the Commission review the checklists used by housing specialists when they complete an annual recertification to ensure the checklist adequately identifies all information required. We also recommend management identify the specialists responsible for the erroneous files and investigate whether findings represent a systemic problem or are limited to a few specialists. Additional training for housing specialists would also improve accuracy. Views of responsible officials: There is no disagreement with the audit finding.
2020-001 Housing Choice Voucher Cluster ? CFDA No. 14.871/14.879 Recommendation: We recommend the Commission review the checklists used by housing specialists when they complete an annual recertification to ensure the checklist adequately identifies all information required. We also recommend that management identify the specialists responsible for the erroneous files and investigate whether findings represent a systemic problem or are limited to a few specialists. Additional training for housing specialists would also improve accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HOC acknowledges the finding and continues to emphasize the importance of daily scanning upon completion of a file. Moreover, staff are held accountable for their actions, as scanning is a performance expectation and measured in the annual review. The HOC hired an internal Staff Trainer in the Housing Resources Division, to provide ongoing education and instructions to new and existing staff. The Trainer will introduce new concepts and re-emphasize existing policies to reduce the error rate and improve the rate of accuracy. Name of the contact person responsible for corrective action: Lynn Hayes, Director of Housing Resources Division (HRD) Planned completion date for corrective action plan: Ongoing
2019-001
During our testing, we noted that the Commission?s internal controls did not always ensure that annual inspections were performed timely and/or properly documented. Questioned costs: Known questioned costs total $21,538. Questioned costs were calculated by determining HAP disbursed to landlords for units during the period of noncompliance with HQS requirements. Context: Out of 40 units tested for annual HQS testing requirements, exceptions were noted for 4 units. 3 units did not have an annual inspection performed within 1 year of the previous inspection and 1 unit had no inspections during fiscal year 2020. The sample was a statistically valid sample. Cause: The Commission did not follow established procedures as documented in its HCVP Administrative Plan to ensure that annual inspections were completed within the required time frame and that all relevant parties were notified of the outcome of the inspections. Effect: The Commission did not perform certain annual inspections in the time frame required by their HCVP Administrative Plan and HUD regulations. The Commission disbursed housing assistance payments to landlords for ineligible units. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2019-002. Recommendation: We recommend the Commission review their annual HQS inspection process to ensure that units are inspected at least once per year. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster CFDA Number: 14.871/14.879 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance, Compliance Criteria or specific requirement: 24 CFR sections 982.158(d) and 982.404(b) states that the PHA must inspect the units leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report. Condition: During our testing, we noted that the Commission?s internal controls did not always ensure that annual inspections were performed timely and/or properly documented. Questioned costs: Known questioned costs total $21,538. Questioned costs were calculated by determining HAP disbursed to landlords for units during the period of noncompliance with HQS requirements. Context: Out of 40 units tested for annual HQS testing requirements, exceptions were noted for 4 units. 3 units did not have an annual inspection performed within 1 year of the previous inspection and 1 unit had no inspections during fiscal year 2020. The sample was a statistically valid sample. Cause: The Commission did not follow established procedures as documented in its HCVP Administrative Plan to ensure that annual inspections were completed within the required time frame and that all relevant parties were notified of the outcome of the inspections. Effect: The Commission did not perform certain annual inspections in the time frame required by their HCVP Administrative Plan and HUD regulations. The Commission disbursed housing assistance payments to landlords for ineligible units. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2019-002. Recommendation: We recommend the Commission review their annual HQS inspection process to ensure that units are inspected at least once per year. Views of responsible officials: There is no disagreement with the audit finding.
2020-002 Housing Choice Voucher Cluster ? CFDA No. 14.871/14.879 Recommendation: We recommend the Commission review their annual HQS inspection process to ensure that units are inspected at least once per year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission continues to make modifications to the inspection procedures in an effort to reduce the number of findings. Effective July 2020, a Financial Analyst began reviewing the inspection records on a monthly basis to prevent missed annual inspections. This added layer will provide oversight of the inspections process. These procedures include but are not limited to, running monthly reports prior to inspection scheduling, monthly review of completed inspections and requests for technology enhancements to assist in the monitoring of inspections. Name of the contact person responsible for corrective action: Renee Harris, Inspections Program Coordinator. Planned completion date for corrective action plan: Ongoing
2019-002
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
During our testing, we noted that the Commission?s internal controls did not always ensure that tenant files included all required documentation. We also noted that income and expenses were not always properly calculated, and as a result, HAP expense was not always properly calculated. Questioned costs: Unable to determine. Context: During our testing of 40 tenant files, exceptions were noted in 7 files. 1 file was missing Declaration of Citizenship forms for 2 household members at the time of the audit; 6 files had either unsubstantiated or unreported income, or income was calculated incorrectly; 3 files contained evidence of bank accounts owned by tenants, but tenants did not report and the Commission did not request self-certification by the tenant or bank statements. As a result of these exceptions, HAP was not calculated correctly for 6 files tested. Cause: The Commission did not follow established procedures as documented in its Administrative Plan to ensure that tenant files included all required documentation and that income and expense was properly calculated. Effect: The Commission did not obtain all required documentation and releases at the time of recertification to support housing assistance payment calculations. The Commission may have made incorrect payments to landlords. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2018-001. Recommendation: We recommend the Commission review the checklists used by housing specialists when they complete an annual recertification to ensure the checklist adequately identifies all information required. We also recommend that management identify the specialists responsible for the erroneous files and investigate whether findings represent a systemic problem or are limited to a few specialists. Additional training for housing specialists would also improve accuracy.
Show full finding ▾Hide full finding ▴2019 ? 001 Federal Agency: U.S.: Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster CFDA Number: 14.871/14.879 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Compliance Criteria or specific requirement: 24 CFR 982.516 requires the PHA to annually obtain and document in the family file the third-party verification of reported family annual income. As a condition of admission or continued occupancy, the PHA must 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). Condition: During our testing, we noted that the Commission?s internal controls did not always ensure that tenant files included all required documentation. We also noted that income and expenses were not always properly calculated, and as a result, HAP expense was not always properly calculated. Questioned costs: Unable to determine. Context: During our testing of 40 tenant files, exceptions were noted in 7 files. 1 file was missing Declaration of Citizenship forms for 2 household members at the time of the audit; 6 files had either unsubstantiated or unreported income, or income was calculated incorrectly; 3 files contained evidence of bank accounts owned by tenants, but tenants did not report and the Commission did not request self-certification by the tenant or bank statements. As a result of these exceptions, HAP was not calculated correctly for 6 files tested. Cause: The Commission did not follow established procedures as documented in its Administrative Plan to ensure that tenant files included all required documentation and that income and expense was properly calculated. Effect: The Commission did not obtain all required documentation and releases at the time of recertification to support housing assistance payment calculations. The Commission may have made incorrect payments to landlords. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2018-001. Recommendation: We recommend the Commission review the checklists used by housing specialists when they complete an annual recertification to ensure the checklist adequately identifies all information required. We also recommend that management identify the specialists responsible for the erroneous files and investigate whether findings represent a systemic problem or are limited to a few specialists. Additional training for housing specialists would also improve accuracy.
2019-001 Housing Choice Voucher Cluster ? CFDA No. 14.871/14.879 Recommendation: We recommend the Commission review the checklists used by housing specialists when they complete an annual recertification to ensure the checklist adequately identifies all information required. We also recommend that management identify the specialists responsible for the erroneous files and investigate whether findings represent a systemic problem or are limited to a few specialists. Additional training for housing specialists would also improve accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission acknowledges the eligibility finding and continues to address the issue. The HRD Management Team along with the Compliance Team will continue to conduct monthly trainings and quality control reviews. Systemic findings will be discussed in monthly staff meetings and non-systemic errors will be addressed individually. Staff with poor performance will be held accountable for their work and counseled pursuant to the HOC Collective Bargaining Agreement and Personnel Policy. Staff have demonstrated improvement in the quality of work, as three of the seven identified errors were for actions processed in fiscal year 2018 though reflected on the fiscal year 2019 HAP register. Name of the contact person responsible for corrective action: Lynn Hayes, Director of Housing Resources Division (HRD) Planned completion date for corrective action plan: Ongoing
2018-001
During our testing, we noted that the Commission?s internal controls did not always ensure that annual inspections or failed inspections were performed timely and/or properly documented. Questioned costs: $29,381 Context: Out of 40 units tested for annual HQS testing requirements, exceptions were noted for 5 units. 5 units did not have an annual inspection performed within 1 year of the previous inspection, 2 of which had no inspection during fiscal year 2019. Cause: The Commission did not follow established procedures as documented in its HCVP Administrative Plan to ensure that inspections and re-inspections were completed within the required time frame and that all relevant parties were notified of the outcome of the inspections. Effect: The Commission did not perform certain annual inspections and re-inspections in the time frame required by their HCVP Administrative Plan and HUD regulations. The Commission disbursed housing assistance payments to landlords for ineligible units. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2018-002. Recommendation: We recommend the Commission review their annual HQS inspection process to ensure that units are inspected at least once per year. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster CFDA Number: 14.871/14.879 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Compliance Criteria or specific requirement: 24 CFR sections 982.158(d) and 982.404(b) states that the PHA must inspect the units leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report. For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. Condition: During our testing, we noted that the Commission?s internal controls did not always ensure that annual inspections or failed inspections were performed timely and/or properly documented. Questioned costs: $29,381 Context: Out of 40 units tested for annual HQS testing requirements, exceptions were noted for 5 units. 5 units did not have an annual inspection performed within 1 year of the previous inspection, 2 of which had no inspection during fiscal year 2019. Cause: The Commission did not follow established procedures as documented in its HCVP Administrative Plan to ensure that inspections and re-inspections were completed within the required time frame and that all relevant parties were notified of the outcome of the inspections. Effect: The Commission did not perform certain annual inspections and re-inspections in the time frame required by their HCVP Administrative Plan and HUD regulations. The Commission disbursed housing assistance payments to landlords for ineligible units. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2018-002. Recommendation: We recommend the Commission review their annual HQS inspection process to ensure that units are inspected at least once per year. Views of responsible officials: There is no disagreement with the audit finding.
2019-002 Housing Choice Voucher Cluster ? CFDA No. 14.871/14.879 Recommendation: We recommend the Commission review their annual HQS inspection process to ensure that units are inspected at least once per year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission has continued to make modifications to the inspection procedures. The modifications include, but are not limited to: ? Regularly meeting with and working close to our third party vendor(s). ? Providing all internal staff with HQS Training. ? Ensuring inspections are scheduled timely. ? Weekly reporting on inspection schedules ? Upgrading the mailing policy to ensure notices are mailed, emailed and detailed inspection information is provided via our external client portal. Name of the contact person responsible for corrective action: Renee Harris, Inspections Program Coordinator. Planned completion date for corrective action plan: Ongoing
2018-002
During our testing, we noted that the Commission?s internal controls did not always ensure that annual inspections were performed timely and/or properly documented. Questioned costs: Unable to determine Context: Out of 40 units tested for Uniform Physical Condition Standards and Inspection Requirements testing, an exception was noted for 1 unit which did not have an annual inspection performed during fiscal year 2019. Cause: The Commission did not follow established procedures as required in the Uniform Physical Condition Standards and Inspection Requirements to ensure that inspections were completed within the required time frame and that all relevant parties were notified of the outcome of the inspections. Effect: The Commission did not perform certain annual inspections in the time frame required by the Uniform Physical Condition Standards and Inspection Requirements. The Commission may have disbursed housing assistance payments to landlords for ineligible units. Repeat Finding: No Recommendation: We recommend the Commission review their Uniform Physical Condition Standards inspection process to ensure that units are inspected at least once per year. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019 ? 003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project Based Cluster CFDA Number: 14.195/14.856 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Compliance Criteria or specific requirement: In accordance with HUD?s Uniform Physical Condition Standards and Inspection Requirements codified in 24 CFR Part 5, Subpart G, and HUD?s Uniform Physical Conditions Standards for Multifamily Properties, codified at 24 CFR Part 200, Subpart P, the Commission must maintain and operate units to provide decent, safe and sanitary housing. The PHA must prepare a unit inspection report. Condition: During our testing, we noted that the Commission?s internal controls did not always ensure that annual inspections were performed timely and/or properly documented. Questioned costs: Unable to determine Context: Out of 40 units tested for Uniform Physical Condition Standards and Inspection Requirements testing, an exception was noted for 1 unit which did not have an annual inspection performed during fiscal year 2019. Cause: The Commission did not follow established procedures as required in the Uniform Physical Condition Standards and Inspection Requirements to ensure that inspections were completed within the required time frame and that all relevant parties were notified of the outcome of the inspections. Effect: The Commission did not perform certain annual inspections in the time frame required by the Uniform Physical Condition Standards and Inspection Requirements. The Commission may have disbursed housing assistance payments to landlords for ineligible units. Repeat Finding: No Recommendation: We recommend the Commission review their Uniform Physical Condition Standards inspection process to ensure that units are inspected at least once per year. Views of responsible officials: There is no disagreement with the audit finding.
2019-003 Section 8 Project Based Cluster ? CFDA No. 14.195/14.856 Recommendation: We recommend the Commission review their annual inspection process to ensure that units are inspected at least once per year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC acknowledges and accepts the finding for not performing an annual inspection on one of our Project Based Cluster units. The Property Management Team along with the Compliance Team will coordinate to ensure proper internal controls are in place to conduct timely annual inspections and quarterly quality control reviews. Name of the contact person responsible for corrective action: Charnita Jackson, Director of Property Management Planned completion date for corrective action plan: Ongoing
FAC accepted this audit on December 4, 2018 — management decision was due June 4, 2019.
GSA_MIGRATION
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2017-001
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2017-002
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FAC accepted this audit on December 7, 2017 — management decision was due June 7, 2018.
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FAC accepted this audit on November 8, 2016 — management decision was due May 8, 2017.
GSA_MIGRATION
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