D.C. HOUSING AUTHORITYLocal Government

EIN: 521934645

UEI: RM4HCLL1LD75

Audited by: SB & COMPANY, LLC

Cognizant agency: 14 [Department of Housing and Urban Development]

Data as of August 27, 2026

D.C. HOUSING AUTHORITY9 audit years41 findings22 repeat
9
Audit Years
41
Total Findings
22
Repeat Findings

FY 2024-09-30

DISCLAIMER OF OPINION$387,544,013 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on June 30, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 30, 2025 (241 days ago).

What is a management decision? →
2024-021
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

• For 11 out of 60 beneficiaries selected for eligibility, the redetermination did not occur within the biennial time period. • For 8 out of 60 beneficiaries selected for eligibility, we were unable to recalculate annual family income listed in the tenant file based up the support provided by management. • For 4 out of 60 beneficiaries selected for eligibility, we were not provided a HUD-50058. Criteria: Beneficiaries must be "low-income families," as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Recommendation We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

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Finding 2024-021 U.S. Department of Housing and Urban Development (HUD) AL No. 14.881 Moving to Work Demonstration Material Weakness in Internal Controls over Compliance for Eligibility Repeat Finding: Yes; 2023-002 Condition: • For 11 out of 60 beneficiaries selected for eligibility, the redetermination did not occur within the biennial time period. • For 8 out of 60 beneficiaries selected for eligibility, we were unable to recalculate annual family income listed in the tenant file based up the support provided by management. • For 4 out of 60 beneficiaries selected for eligibility, we were not provided a HUD-50058. Criteria: Beneficiaries must be "low-income families," as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Recommendation We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

Corrective Action Plan

Finding 2024-021 U.S. Department of Housing and Urban Development (HUD) AL No. 14.881 Moving to Work Demonstration Material Weakness in Internal Control over Compliance for Eligibility Repeat Finding: Yes; 2023-002 Auditee’s Corrective Action Plan: DCHA has increased their quality control department to ensure that file reviews are completed and stored electronically in the Yardi system. In addition, DCHA has engaged with several consulting groups to assist in the backlog of recertifications while the current staff works on the current recertifications so they do not become past due like in the past. Contact Person: Anton Shaw, Director, Housing Choice Voucher Program Completion Date: September 30, 2026

Prior Finding References

2023-002

About Eligibility →
2024-022
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

• For 13 out of 60 beneficiaries selected for eligibility, the redetermination did not occur within the biennial time period. • For 2 out of 60 beneficiaries selected for eligibility, we did not observe 3rd party verification of reported income. Criteria 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 section 982.516). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent or HAP may have been miscalculated due to using incorrect information in the recalculations. Tenant recertifications were not shown to be performed on a timely basis. Recommendation We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

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Finding 2024-022 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Eligibility Repeat Finding: Yes; 2023-003 Condition: • For 13 out of 60 beneficiaries selected for eligibility, the redetermination did not occur within the biennial time period. • For 2 out of 60 beneficiaries selected for eligibility, we did not observe 3rd party verification of reported income. Criteria 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 section 982.516). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent or HAP may have been miscalculated due to using incorrect information in the recalculations. Tenant recertifications were not shown to be performed on a timely basis. Recommendation We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

Corrective Action Plan

Finding 2024-022 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Control over Compliance for Eligibility Repeat Finding: Yes; 2023-003 Auditee’s Corrective Action Plan: DCHA has increased their quality control department to ensure that file reviews are completed and stored electronically in the Yardi system. In addition, DCHA has engaged with several consulting groups to assist in the backlog of recertifications while the current staff works on the current recertifications so they do not become past due like in the past. Third party vendors have been brought onboard to assist with processing all past due biennial recertifications. Contact Person: Anton Shaw, Director, Housing Choice Voucher Program Completion Date: September 30, 2026

Prior Finding References

2023-003

About Eligibility →
2024-023
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Finding 2024-023 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions – HQS Enforcement Repeat Finding: Yes; 2023-004 Condition • For 47 of 60 files tested, the reinspection was not completed within the required timeframe. Additionally, the Authority did not place the unit under abatement and stop HAP during this period. • For 7 of 60 files tested, the unit failed reinspection and there was no documentation that the unit was properly placed under abatement. Criteria When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Questioned Costs Unknown. Cause The Authority did not reinspect or abate units timely. Effect The Authority is not in compliance with HQS enforcement requirements. Recommendation We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated. Finding 2024-024 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions - HQS Repeat Finding: Yes; 2023-005 Condition • For 8 of the 60 samples, we were unable to view biennial inspections being performed. Criteria The 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 982.158(d) and 982.405(b)). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect The Authority is not in compliance with federal regulations regarding HQS inspections. Recommendation We recommend the Authority implements controls to ensure that HOS inspections are completed in accordance with their administrative plan. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

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Finding 2024-023 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions – HQS Enforcement Repeat Finding: Yes; 2023-004 Condition • For 47 of 60 files tested, the reinspection was not completed within the required timeframe. Additionally, the Authority did not place the unit under abatement and stop HAP during this period. • For 7 of 60 files tested, the unit failed reinspection and there was no documentation that the unit was properly placed under abatement. Criteria When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Questioned Costs Unknown. Cause The Authority did not reinspect or abate units timely. Effect The Authority is not in compliance with HQS enforcement requirements. Recommendation We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated. Finding 2024-024 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions - HQS Repeat Finding: Yes; 2023-005 Condition • For 8 of the 60 samples, we were unable to view biennial inspections being performed. Criteria The 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 982.158(d) and 982.405(b)). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect The Authority is not in compliance with federal regulations regarding HQS inspections. Recommendation We recommend the Authority implements controls to ensure that HOS inspections are completed in accordance with their administrative plan. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

Corrective Action Plan

Finding 2024-023 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Control over Compliance for Special Tests and Provisions – HQS Enforcement Repeat Finding: Yes; 2023-004 Auditee’s Corrective Action Plan: The HCVP Inspections department has begun a department reorganization which includes updating Standard Operating Procedures (SOPs), enhancement to the Yardi inspections module, and training. The reorganization will allow oversight of DCHA inspection team and contracted inspection staff that was brought on to assist the backlog of annual inspections. Quality control measures have also been put into place to monitor the Yardi system of timely inspections, reinspections, and/or abatements. Contact Person: Anton Shaw, Director, Housing Choice Voucher Program Completion Date: September 30, 2026

Prior Finding References

2023-004

About Special Tests and Provisions →
2024-024
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Finding 2024-023 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions – HQS Enforcement Repeat Finding: Yes; 2023-004 Condition • For 47 of 60 files tested, the reinspection was not completed within the required timeframe. Additionally, the Authority did not place the unit under abatement and stop HAP during this period. • For 7 of 60 files tested, the unit failed reinspection and there was no documentation that the unit was properly placed under abatement. Criteria When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Questioned Costs Unknown. Cause The Authority did not reinspect or abate units timely. Effect The Authority is not in compliance with HQS enforcement requirements. Recommendation We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated. Finding 2024-024 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions - HQS Repeat Finding: Yes; 2023-005 Condition • For 8 of the 60 samples, we were unable to view biennial inspections being performed. Criteria The 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 982.158(d) and 982.405(b)). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect The Authority is not in compliance with federal regulations regarding HQS inspections. Recommendation We recommend the Authority implements controls to ensure that HOS inspections are completed in accordance with their administrative plan. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

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Finding 2024-023 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions – HQS Enforcement Repeat Finding: Yes; 2023-004 Condition • For 47 of 60 files tested, the reinspection was not completed within the required timeframe. Additionally, the Authority did not place the unit under abatement and stop HAP during this period. • For 7 of 60 files tested, the unit failed reinspection and there was no documentation that the unit was properly placed under abatement. Criteria When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Questioned Costs Unknown. Cause The Authority did not reinspect or abate units timely. Effect The Authority is not in compliance with HQS enforcement requirements. Recommendation We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated. Finding 2024-024 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance for Special Tests and Provisions - HQS Repeat Finding: Yes; 2023-005 Condition • For 8 of the 60 samples, we were unable to view biennial inspections being performed. Criteria The 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 982.158(d) and 982.405(b)). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect The Authority is not in compliance with federal regulations regarding HQS inspections. Recommendation We recommend the Authority implements controls to ensure that HOS inspections are completed in accordance with their administrative plan. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

Corrective Action Plan

Finding 2024-024 U.S. Department of Housing and Urban Development (HUD) AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Control over Compliance for Special Tests and Provisions - HQS Repeat Finding: Yes; 2023-005 Auditee’s Corrective Action Plan: DCHA reviewed the eight tested, and they will be completed in accordance to the DCHA Admin plan which will be completed in FY 2025. Contact Person: Anton Shaw, Director, Housing Choice Voucher Program Completion Date: September 30, 2025

Prior Finding References

2023-005

About Special Tests and Provisions →
2024-025
Special Tests & Provisions
MATERIAL WEAKNESSREPEATOTHER MATTERS

Finding: 2024-025 U.S. Department of Housing and Urban Development AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance/ Material Noncompliance for Special Tests and Provisions – Rent Reasonableness Repeat Finding: Yes 2023-007 Condition • For 3 of the 60 files tested, the amount documented as the reasonable rent was less than the rent to the owner noted on the HUD-50058. • For 7 of the 60 files tested, we were not provided with proper documentation to determine that the rent comparability was performed. Criteria The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract: (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). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with reasonable rent requirements. Effect The Authority is not in compliance with federal regulations regarding the required reasonable rent requirements. Recommendation We recommend the Authority implements controls to ensure that the rent to owner is reasonable in accordance with their administrative plan. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

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Finding: 2024-025 U.S. Department of Housing and Urban Development AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Controls over Compliance/ Material Noncompliance for Special Tests and Provisions – Rent Reasonableness Repeat Finding: Yes 2023-007 Condition • For 3 of the 60 files tested, the amount documented as the reasonable rent was less than the rent to the owner noted on the HUD-50058. • For 7 of the 60 files tested, we were not provided with proper documentation to determine that the rent comparability was performed. Criteria The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract: (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). Questioned Costs Unknown. Cause The Authority did not sufficiently monitor controls to ensure compliance with reasonable rent requirements. Effect The Authority is not in compliance with federal regulations regarding the required reasonable rent requirements. Recommendation We recommend the Authority implements controls to ensure that the rent to owner is reasonable in accordance with their administrative plan. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in this report. Auditor’s Conclusion: Finding remains as stated.

Corrective Action Plan

Finding: 2024-025 U.S. Department of Housing and Urban Development AL No. 14.871/14.879 Housing Voucher Cluster Material Weakness in Internal Control over Compliance/ Material Noncompliance for Special Tests and Provisions – Rent Reasonableness Repeat Finding: Yes 2023-007 Auditee’s Corrective Action Plan: DCHA has implemented controls to ensure rent to the owner is reasonable and in accordance to our admin plan. All rent reasonableness files are housed in the rent reasonableness software- AffordableHousing.com. DCHA has a policy in place for rent reasonableness, and all rent reasonable comparability studies are housed in the software system. Contact Person:Anton Shaw, Director, Housing Choice Voucher Program Completion Date: September 30, 2026

Prior Finding References

2023-007

About Special Tests and Provisions →

FY 2023-09-30

$381,577,843 federal awards expended

FAC accepted this audit on August 16, 2024 — management decision was due February 16, 2025.

2023-002
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-LRPH (40) and MTW-HCV (40) found exceptions in 10 of the 40 MTW-LRPH files tested and 13 of the 40 MTW-HCV files tested. The following MTW-LRPH exceptions were noted: • For 5 of 40 files tested, support was provided, however, CLA did not observe a HUD-50058 with an effective date prior to, and effective for, the rent payment pulled from rent roll. As a result, we were unable to test the sample. • For 4 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 1 of 40 files tested, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 1 of 40 tenant files tested, we did not observe a recertification checklist, or the signed Application for Applied Occupancy completed by the specialist. The following MTW-HCV exceptions were noted: • For 1 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 5 of the 40 files tested we were unable to determine that recertifications were completed on a biennial basis. • For 8 of the 40 files tested, we were not provided with the quality control checklist signed by a housing assistant specialist. • For 1 of the 40 files tested, the HAP per the HUD-50058 did not agree to the HAP payment selected for testing; as a result, we were unable to verify the supporting documentation provided was for the HAP payment selected. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2022-002 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-LRPH (40) and MTW-HCV (40) found exceptions in 10 of the 40 MTW-LRPH files tested and 13 of the 40 MTW-HCV files tested. The following MTW-LRPH exceptions were noted: • For 5 of 40 files tested, support was provided, however, CLA did not observe a HUD-50058 with an effective date prior to, and effective for, the rent payment pulled from rent roll. As a result, we were unable to test the sample. • For 4 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 1 of 40 files tested, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 1 of 40 tenant files tested, we did not observe a recertification checklist, or the signed Application for Applied Occupancy completed by the specialist. The following MTW-HCV exceptions were noted: • For 1 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 5 of the 40 files tested we were unable to determine that recertifications were completed on a biennial basis. • For 8 of the 40 files tested, we were not provided with the quality control checklist signed by a housing assistant specialist. • For 1 of the 40 files tested, the HAP per the HUD-50058 did not agree to the HAP payment selected for testing; as a result, we were unable to verify the supporting documentation provided was for the HAP payment selected. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2022-002 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP has a program eligibility team that processes applications, and once complete, the file is reviewed by a quality control and compliance officer for compliance. The Office of Audit and Compliance (OAC) shall periodically monitor this process to ensure that eligibility determination documentation is complete, accurate, and available for audit. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24

Prior Finding References

2022-002

About Eligibility →
2023-003
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 section 982.516). Condition/Context: Exceptions noted in 27 out of 40 non-MTW HCV files tested: • For 3 of 40 files tested, we were not provided with any supporting documentation to verify eligibility. • For 13 of 40 samples, we were unable to recalculate the income total listed on the HUD-50058 based on the income support provided. • For 11 of 40 samples, we did not observe 3rd party verification of reported income. • For 4 of 40 samples, we did not observe 3rd party verification of reported assets. • For 4 of 40 samples, we did not observe documentation showing that the head of household was the parent or legal guardian to a dependent for which an allowance was granted or we did not receive documentation for medical expenses. • For 14 of 40 samples, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 11 of 40 samples, we did not observe the "Authorization for Release of Information/Privacy Act Notice form (HUD-9886) singed by the tenant and all members in the household over the age of 18 for the recertification date listed. • For 5 of 40 samples, we did not observe the general release form signed by the tenant and all members in the household over the age of 18, allowing the Authority to obtain information from third parties. • For 8 of 40 samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent or HAP may have been miscalculated due to using incorrect information in the recalculations. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2022-003 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 section 982.516). Condition/Context: Exceptions noted in 27 out of 40 non-MTW HCV files tested: • For 3 of 40 files tested, we were not provided with any supporting documentation to verify eligibility. • For 13 of 40 samples, we were unable to recalculate the income total listed on the HUD-50058 based on the income support provided. • For 11 of 40 samples, we did not observe 3rd party verification of reported income. • For 4 of 40 samples, we did not observe 3rd party verification of reported assets. • For 4 of 40 samples, we did not observe documentation showing that the head of household was the parent or legal guardian to a dependent for which an allowance was granted or we did not receive documentation for medical expenses. • For 14 of 40 samples, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 11 of 40 samples, we did not observe the "Authorization for Release of Information/Privacy Act Notice form (HUD-9886) singed by the tenant and all members in the household over the age of 18 for the recertification date listed. • For 5 of 40 samples, we did not observe the general release form signed by the tenant and all members in the household over the age of 18, allowing the Authority to obtain information from third parties. • For 8 of 40 samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent or HAP may have been miscalculated due to using incorrect information in the recalculations. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2022-003 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP has a program eligibility team that processes applications. Once completed, the file will be reviewed monthly by an HCVP quality control staff and quarterly by the OAC to ensure that documentation is complete, accurate, and available for audit. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24

Prior Finding References

2022-003

About Eligibility →
2023-004
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition/Context: Exceptions noted in 22 of 22 files tested: • For 21 of 22 files tested, the file did not include the results letter to document the failed inspection and the required correction period for any deficiencies. • For 19 of 22 files tested, the file did not contain a pass inspection report documenting repairs were completed. • For 19 of 22 files tested, the file did not contain documentation that the unit was properly placed under abatement and/or HAP was not paid under the abatement period. • For 19 of 22 files tested, the file did not contain documentation showing whether the tenant failed to correct deficiencies and that the PHA took proper steps to enforce the family obligations. Questioned Costs: Unable to determine. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: The finding is a repeat of finding 2022-004 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition/Context: Exceptions noted in 22 of 22 files tested: • For 21 of 22 files tested, the file did not include the results letter to document the failed inspection and the required correction period for any deficiencies. • For 19 of 22 files tested, the file did not contain a pass inspection report documenting repairs were completed. • For 19 of 22 files tested, the file did not contain documentation that the unit was properly placed under abatement and/or HAP was not paid under the abatement period. • For 19 of 22 files tested, the file did not contain documentation showing whether the tenant failed to correct deficiencies and that the PHA took proper steps to enforce the family obligations. Questioned Costs: Unable to determine. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: The finding is a repeat of finding 2022-004 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP created a dedicated phone line and email address to log and document inspections weekly. A designated staff member was assigned to review all inspection reports and findings, as well as to monitor the dedicated phone line and email address on a weekly basis. The OAC shall monitor this process monthly. Name of the contact person responsible for corrective action: Joseph Atkins Planned completion date for corrective action plan: 6/30/2024.

Prior Finding References

2022-004

About Special Tests and Provisions →
2023-005
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition/Context: Exceptions noted in 29 of 40 units: • For 29 of the 40 samples, we were unable to view biennial inspections being performed. • For 29 of the 40 samples, we were unable to view that HQS inspections were completed in accordance with the HCVP Admin plan. • For 18 of the 40 samples, we did not receive the completed letter from the DCHA specialists notifying the landlord and tenant in writing of the inspection. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding HQS inspections. Repeat Finding: The finding is a repeat of finding 2022-005 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition/Context: Exceptions noted in 29 of 40 units: • For 29 of the 40 samples, we were unable to view biennial inspections being performed. • For 29 of the 40 samples, we were unable to view that HQS inspections were completed in accordance with the HCVP Admin plan. • For 18 of the 40 samples, we did not receive the completed letter from the DCHA specialists notifying the landlord and tenant in writing of the inspection. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding HQS inspections. Repeat Finding: The finding is a repeat of finding 2022-005 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP created a dedicated phone line and email address to log and document inspections weekly. A designated staff member was assigned to review all inspection reports and findings, as well as to monitor the dedicated phone line and email address on a weekly basis. The OAC shall monitor this process monthly. Name of the contact person responsible for corrective action: Joseph Atkins. Planned completion date for corrective action plan: 6/30/24.

Prior Finding References

2022-005

About Special Tests and Provisions →
2023-006
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition/Context: Exceptions noted in 14 of the 40 samples: • For 13 of the 40 files tested, we were not provided with the voucher issuance or denial letter applicable, nor was the application signed or electronically signed. • For 1 of the 40 files tested, we were not provided with supporting documentation. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with new tenant selection requirements. Effect: The Authority is not in compliance with federal regulations regarding the required new tenant selection requirements. Repeat Finding: The finding is a repeat of finding 2022-006 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained for new tenants. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition/Context: Exceptions noted in 14 of the 40 samples: • For 13 of the 40 files tested, we were not provided with the voucher issuance or denial letter applicable, nor was the application signed or electronically signed. • For 1 of the 40 files tested, we were not provided with supporting documentation. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with new tenant selection requirements. Effect: The Authority is not in compliance with federal regulations regarding the required new tenant selection requirements. Repeat Finding: The finding is a repeat of finding 2022-006 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained for new tenants. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained for new tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP is implementing a monthly quality control protocol to review new applicant files for completeness. A new Program Director was assigned to oversee this quality control process. The Program Director will also monitor the new tenant checklist which will be created to ensure that all new tenant documentation is accurately maintained. The OAC shall monitor and collaborate with the HCVP to ensure that the checklist is accurate and available for auditing. Name of the contact person responsible for corrective action: Starr Lane. Planned completion date for corrective action plan: 7/31/24.

Prior Finding References

2022-006

About Special Tests and Provisions →
2023-007
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (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/Context: Exceptions noted in 12 of the 35 samples selected for new tenants: • For 6 of the 35 files tested, we were unable to determine that the rent was determined reasonable for the unit in accordance with the administrative plan. • For 12 of the 35 files tested, we were not provided with proper documentation to determine that the rent comparability was performed prior to the effective date. We were not provided documentation for 3 of the 10 files tested for contract rent changes during the term of the HAP contract. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reasonable rent requirements. Effect: The Authority is not in compliance with federal regulations regarding the required reasonable rent requirements. Repeat Finding: The finding is a repeat of finding 2022-007 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that the rent to owner is reasonable in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (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/Context: Exceptions noted in 12 of the 35 samples selected for new tenants: • For 6 of the 35 files tested, we were unable to determine that the rent was determined reasonable for the unit in accordance with the administrative plan. • For 12 of the 35 files tested, we were not provided with proper documentation to determine that the rent comparability was performed prior to the effective date. We were not provided documentation for 3 of the 10 files tested for contract rent changes during the term of the HAP contract. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reasonable rent requirements. Effect: The Authority is not in compliance with federal regulations regarding the required reasonable rent requirements. Repeat Finding: The finding is a repeat of finding 2022-007 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that the rent to owner is reasonable in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the rent to the owner is reasonable in accordance with their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP hired a third-party vendor, AffordableHousing.com, to conduct all rent reasonableness of all housing units that are presented for leasing, to ensure that the rent to owner is reasonable and in accordance with the administrative plan. The OAC shall monitor the compliance monthly. Name of the contact person responsible for corrective action: Ockeshia Pompey Planned completion date for corrective action plan: 7/31/24.

Prior Finding References

2022-007

About Special Tests and Provisions →
2023-008
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEATOTHER MATTERS

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition/Context: Exceptions noted in 13 of the 40 files tested: • For 1 of the 40 files tested, we were not provided with any of the documentation requested. • For 5 of the 40 files tested, the HAP amount on the HUD-50058 did not equal the amount included in the HAP register. • For 10 of the 40 files tested, we were not provided with the signed checklist. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with HAP contract and register requirements. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: The finding is a repeat of finding 2022-008 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that files are maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition/Context: Exceptions noted in 13 of the 40 files tested: • For 1 of the 40 files tested, we were not provided with any of the documentation requested. • For 5 of the 40 files tested, the HAP amount on the HUD-50058 did not equal the amount included in the HAP register. • For 10 of the 40 files tested, we were not provided with the signed checklist. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with HAP contract and register requirements. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: The finding is a repeat of finding 2022-008 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that files are maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that files are maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP is implementing a monthly quality control protocol to review new applicant files for completeness. A new Program Director was assigned to oversee this quality control process. The Program Director will also monitor the new tenant checklist which will be created to ensure that all new tenant documentation is accurately maintained. The OAC shall monitor and collaborate with the HCVP to ensure that the checklist is accurate and available for auditing. Name of the contact person responsible for corrective action: Starr Lane Planned completion date for corrective action plan: 7/31/24.

Prior Finding References

2022-008

About Special Tests and Provisions →
2023-009
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: PHA's must submit timely GAAP-based unaudited and audited financial information electronically to HUD (see Section 13, Moving to Work (MTW) Agencies Reporting to FASS-PH, of Notice PIH-2012-21 (HA), issued May 10, 2012). Condition/Context: Exception noted for the timeliness of the submission. Questioned Costs: Unable to determine. Cause: The Authority did not submit their financial report to HUD in a timely manner. Effect: The Authority is not in compliance with financial reporting requirements. Repeat Finding: The finding is a repeat of finding 2022-009 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that financial reporting is completed and submitted timely. Views of Responsible Officials: There is no disagreement with the audit finding

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: PHA's must submit timely GAAP-based unaudited and audited financial information electronically to HUD (see Section 13, Moving to Work (MTW) Agencies Reporting to FASS-PH, of Notice PIH-2012-21 (HA), issued May 10, 2012). Condition/Context: Exception noted for the timeliness of the submission. Questioned Costs: Unable to determine. Cause: The Authority did not submit their financial report to HUD in a timely manner. Effect: The Authority is not in compliance with financial reporting requirements. Repeat Finding: The finding is a repeat of finding 2022-009 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that financial reporting is completed and submitted timely. Views of Responsible Officials: There is no disagreement with the audit finding

Corrective Action Plan

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements controls to ensure that financial reporting is completed and submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: OFM leadership is updating the financial policies and procedures to include standard operating procedures (SOP) to accommodate the new Yardi financial software system. These SOPs will include a monthly closing checklist process that will be implemented to ensure that the financial reports are prepared and submitted in a timely manner. Name of the contact person responsible for corrective action: Heather Mueller. Planned completion date for corrective action plan: 09/30/2024.

Prior Finding References

2022-009

About Reporting →
2023-010
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: MTW Agencies must ensure that housing assisted under the demonstration program meets housing quality standards established or approved by the Secretary. The HCV program regulations at 24 CFR sections 982.401 through 982.405 set forth basic housing quality standards (HQS) which all units must meet, and the PHA must verify by inspection, before initial assistance can be paid on behalf of a family and at least annually throughout the term of the assisted tenancy. Current HQS regulations consist of 13 key aspects of housing quality, performance requirements, and acceptability criteria to meet each performance requirement. HQS include requirements for all housing types, including single and multi-family dwelling units, as well as specific requirements for special housing types, such as manufactured homes, congregate housing, single room occupancy, shared housing, and group residences (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: For 4 of the 40 files tested, we were unable to view support for biennial inspections being performed. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding HQS inspections. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their admin plan. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: MTW Agencies must ensure that housing assisted under the demonstration program meets housing quality standards established or approved by the Secretary. The HCV program regulations at 24 CFR sections 982.401 through 982.405 set forth basic housing quality standards (HQS) which all units must meet, and the PHA must verify by inspection, before initial assistance can be paid on behalf of a family and at least annually throughout the term of the assisted tenancy. Current HQS regulations consist of 13 key aspects of housing quality, performance requirements, and acceptability criteria to meet each performance requirement. HQS include requirements for all housing types, including single and multi-family dwelling units, as well as specific requirements for special housing types, such as manufactured homes, congregate housing, single room occupancy, shared housing, and group residences (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: For 4 of the 40 files tested, we were unable to view support for biennial inspections being performed. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding HQS inspections. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their admin plan. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their admin plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP created a dedicated phone line and email address to log and document inspections weekly. A designated staff member was assigned to review all inspection reports and findings, as well as to monitor the dedicated phone line and email address on a weekly basis. Name of the contact person responsible for corrective action: Joseph Atkins Planned completion date for corrective action plan: 6/30/24.

About Special Tests and Provisions →
2023-011
Reporting / Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: PHAs may use HCVP and MV funds only for HAPs to participating owners, and for associated administrative fees (24 CFR sections 982.151 and 982.152). Accumulated administrative fees prior to fiscal year 2004, may be used for any housing-related purpose. Unspent administrative fees accumulated post fiscal year 2003 (i.e., fees from fiscal year 2004 and later funding, see III.L.1.e.(4)(a), “Financial Reporting –Financial Reports”) may be used only to support the HCVP. These funds still are considered to be administrative fee reserves and are subject to all of the requirements applicable to administrative fee reserves including, but not limited to, those in 24 CFR section 982.155. The fees accumulated from fiscal year 2004 and later funding must be used for activities related to the provision of tenant-based rental assistance authorized under Section 8 of the United States Housing Act of 1937, including related development activities. PHAs must maintain and report balances for both funding sources (see notice PIH 2015-17 (HA) dated October 6, 2015) (Division I, Title II, Section (5) of Consolidated Appropriations Act, 2005, Pub. L. No. 108-447, 118 Stat. 3296, and subsequent appropriations acts; see Section 5 of Notice PIH 2005-01; 24 CFR section 982.155). Condition/Context: An unallowable transfer of administrative fees was noted and corrected during the audit. Questioned Costs: $1,059,302 Cause: The Authority did not sufficiently monitor controls to ensure compliance with allowable transfer requirements. Effect: The Authority is not in compliance with federal regulations related to allowable transfer requirements. Repeat Finding: No. Recommendation: We recommend management the Authority implements controls to ensure that transfers are not made out of the program. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: PHAs may use HCVP and MV funds only for HAPs to participating owners, and for associated administrative fees (24 CFR sections 982.151 and 982.152). Accumulated administrative fees prior to fiscal year 2004, may be used for any housing-related purpose. Unspent administrative fees accumulated post fiscal year 2003 (i.e., fees from fiscal year 2004 and later funding, see III.L.1.e.(4)(a), “Financial Reporting –Financial Reports”) may be used only to support the HCVP. These funds still are considered to be administrative fee reserves and are subject to all of the requirements applicable to administrative fee reserves including, but not limited to, those in 24 CFR section 982.155. The fees accumulated from fiscal year 2004 and later funding must be used for activities related to the provision of tenant-based rental assistance authorized under Section 8 of the United States Housing Act of 1937, including related development activities. PHAs must maintain and report balances for both funding sources (see notice PIH 2015-17 (HA) dated October 6, 2015) (Division I, Title II, Section (5) of Consolidated Appropriations Act, 2005, Pub. L. No. 108-447, 118 Stat. 3296, and subsequent appropriations acts; see Section 5 of Notice PIH 2005-01; 24 CFR section 982.155). Condition/Context: An unallowable transfer of administrative fees was noted and corrected during the audit. Questioned Costs: $1,059,302 Cause: The Authority did not sufficiently monitor controls to ensure compliance with allowable transfer requirements. Effect: The Authority is not in compliance with federal regulations related to allowable transfer requirements. Repeat Finding: No. Recommendation: We recommend management the Authority implements controls to ensure that transfers are not made out of the program. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend management the Authority implements controls to ensure that transfers are not made out of the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: OFM leadership is updating the financial policies and procedures to include standard operating procedures (SOP) to accommodate the new Yardi financial software system. These SOPs will include a transfer of funds to the proper program process that will be implemented to ensure that the any fund transfer should be reviewed and approved by the financial managers. Name of the contact person responsible for corrective action: Heather Mueller. Planned completion date for corrective action plan: 09/30/2024.

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2023-012
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA is required to submit this 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. 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/Context: Exceptions noted in 4 of the 40 samples. Exceptions included discrepancies between the HUD-50058 and the uploaded recertification and lack of support provided. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements. Effect: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Repeat Finding: The finding is a repeat of finding 2022-011 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA is required to submit this 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. 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/Context: Exceptions noted in 4 of the 40 samples. Exceptions included discrepancies between the HUD-50058 and the uploaded recertification and lack of support provided. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements. Effect: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Repeat Finding: The finding is a repeat of finding 2022-011 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP shall recruit and hire a dedicated Data Analyst to oversee the PIC entries and to ensure that recertifications are uploaded in accordance with reporting requirements. The PIC uploads will be quality-controlled monthly by HCVP and quarterly by the OAC. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24.

Prior Finding References

2022-011

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2023-013
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions noted in 3 of the 40 samples. Exceptions included discrepancies between the HUD-50058 and the uploaded recertification and lack of support provided. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with PIC reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: The finding is a repeat of finding 2022-012 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2023 Award Period: October 1, 2022 – September 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions noted in 3 of the 40 samples. Exceptions included discrepancies between the HUD-50058 and the uploaded recertification and lack of support provided. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with PIC reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: The finding is a repeat of finding 2022-012 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP shall recruit and hire a dedicated Data Analyst to oversee the PIC entries and to ensure that recertifications are uploaded in accordance with reporting requirements. The PIC uploads will be quality-controlled monthly by HCVP and quarterly by the Office of Audit and Compliance. The OAC will conduct monthly checks to ensure that the uploads are done to facilitate the required reporting. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24.

Prior Finding References

2022-012

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FY 2022-09-30

$354,267,588 federal awards expended

FAC accepted this audit on July 22, 2024 — management decision was due January 22, 2025.

2022-002
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

2022– 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-LRPH (40) and MTW HCV (40) found exceptions in 25 of the 40 MTW-LRPH files tested and 23 of the 40 MTW-HCV files tested. The following MTW-LRPH exceptions were noted: • For 1 of 40 files tested, we were not provided with any supporting documentation to verify eligibility. • For 7 of 40 files tested, support was provided, however, CLA did not observe a HUD-50058 with an effective date prior to, and effective for, the rent payment pulled from rent roll. • For 6 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 12 of 40 files tested, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 5 of 40 tenant files tested, we did not observe a recertification checklist, or the signed Application for Applied Occupancy completed by the specialist. The following MTW-HCV exceptions were noted: • For 3 of 40 files tested, supporting documentation was not provided. • For 12 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 10 of the 40 files tested we were unable to determine that recertifications were completed on a biennial basis. • For 2 of the 40 files tested, we were not provided with the quality control checklist signed by a housing assistant specialist. • For 3 of the 40 files tested, the HAP per the HUD-50058 did not agree to the HAP register. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2021-002 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022– 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-LRPH (40) and MTW HCV (40) found exceptions in 25 of the 40 MTW-LRPH files tested and 23 of the 40 MTW-HCV files tested. The following MTW-LRPH exceptions were noted: • For 1 of 40 files tested, we were not provided with any supporting documentation to verify eligibility. • For 7 of 40 files tested, support was provided, however, CLA did not observe a HUD-50058 with an effective date prior to, and effective for, the rent payment pulled from rent roll. • For 6 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 12 of 40 files tested, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 5 of 40 tenant files tested, we did not observe a recertification checklist, or the signed Application for Applied Occupancy completed by the specialist. The following MTW-HCV exceptions were noted: • For 3 of 40 files tested, supporting documentation was not provided. • For 12 of the 40 files tested, we were unable to recalculate annual family income listed in the tenant file to the backup support provided. We either did not observe backing support to recalculate the annual income listed on the tested HUD-50058 or we did not receive the EIV report. • For 10 of the 40 files tested we were unable to determine that recertifications were completed on a biennial basis. • For 2 of the 40 files tested, we were not provided with the quality control checklist signed by a housing assistant specialist. • For 3 of the 40 files tested, the HAP per the HUD-50058 did not agree to the HAP register. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2021-002 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-002 Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP has a program eligibility team that processes applications, and once complete, the file is reviewed by a quality control and compliance officer for compliance. The Office of Audit and Compliance (OAC) shall periodically monitor this process to ensure that eligibility determination documentation is complete, accurate, and available for audit. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24.

Prior Finding References

2021-002

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2022-003
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

2022 – 003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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 section 982.516). Condition/Context: Exceptions noted in 35 out of 40 non-MTW HCV files tested: • For 1 of 40 files tested, we were not provided with any supporting documentation to verify eligibility. • For 30 of 40 samples, we were unable to recalculate the income total listed on the HUD-50058 based on the income support provided. • For 8 of 40 samples, we did not observe documentation showing that the head of household was the parent or legal guardian to a dependent for which an allowance was granted or we did not receive documentation for medical expenses. • For 7 of 40 samples, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 7 of 40 samples, we did not observe the "Authorization for Release of Information/Privacy Act Notice form (HUD-9886) singed by the tenant and all members in the household over the age of 18 for the recertification date listed. • For 9 of 40 samples, we did not observe the general release form signed by the tenant and all members in the household over the age of 18, allowing the Authority to obtain information from third parties. • For 10 of 40 samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2021-003 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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 section 982.516). Condition/Context: Exceptions noted in 35 out of 40 non-MTW HCV files tested: • For 1 of 40 files tested, we were not provided with any supporting documentation to verify eligibility. • For 30 of 40 samples, we were unable to recalculate the income total listed on the HUD-50058 based on the income support provided. • For 8 of 40 samples, we did not observe documentation showing that the head of household was the parent or legal guardian to a dependent for which an allowance was granted or we did not receive documentation for medical expenses. • For 7 of 40 samples, we did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis. • For 7 of 40 samples, we did not observe the "Authorization for Release of Information/Privacy Act Notice form (HUD-9886) singed by the tenant and all members in the household over the age of 18 for the recertification date listed. • For 9 of 40 samples, we did not observe the general release form signed by the tenant and all members in the household over the age of 18, allowing the Authority to obtain information from third parties. • For 10 of 40 samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2021-003 in the prior audit period. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-003 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP has a program eligibility team that processes applications. Once completed, the file will be reviewed monthly by an HCVP quality control staff and quarterly by the OAC to ensure that documentation is complete, accurate, and available for audit. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24.

Prior Finding References

2021-003

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2022-004
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

2022 – 004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition/Context: Exceptions noted in 35 of 40 files tested: • For 20 of 40 files tested, the file did not include the results letter to document the failed inspection and the required correction period for any deficiencies. • For 24 of 40 files tested, the file did not include a copy of the completed letter from DCHA specialists notifying the landlord and tenant in writing of the inspection. • For 23 of 40 files tested, the file did not contain a pass inspection report documenting repairs were completed. • For 30 of 40 files tested, the file did not contain documentation that the unit was properly placed under abatement and/or HAP was not paid under the abatement period. • For 25 of 40 files tested, the file did not contain documentation showing whether the tenant failed to correct deficiencies and that the PHA took proper steps to enforce the family obligations. Questioned Costs: Unable to determine. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: The finding is a repeat of finding 2021-004 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: When performing HQS inspections that result in an owner failed to correct cited HQS deficiencies within a specified time frame, the PHA must show that it properly stopped (abated) HAPs or terminated the HAP contract (24 CFR sections 982.158(d) and 982.404). Condition/Context: Exceptions noted in 35 of 40 files tested: • For 20 of 40 files tested, the file did not include the results letter to document the failed inspection and the required correction period for any deficiencies. • For 24 of 40 files tested, the file did not include a copy of the completed letter from DCHA specialists notifying the landlord and tenant in writing of the inspection. • For 23 of 40 files tested, the file did not contain a pass inspection report documenting repairs were completed. • For 30 of 40 files tested, the file did not contain documentation that the unit was properly placed under abatement and/or HAP was not paid under the abatement period. • For 25 of 40 files tested, the file did not contain documentation showing whether the tenant failed to correct deficiencies and that the PHA took proper steps to enforce the family obligations. Questioned Costs: Unable to determine. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: The finding is a repeat of finding 2021-004 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-004 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP created a dedicated phone line and email address to log and document inspections weekly. A designated staff member was assigned to review all inspection reports and findings, as well as to monitor the dedicated phone line and email address on a weekly basis. The OAC shall monitor this process on a monthly basis. Name of the contact person responsible for corrective action: Joseph Atkins Planned completion date for corrective action plan: 6/30/2024

Prior Finding References

2021-004

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2022-005
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

2022 – 005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition/Context: Exceptions noted in 35 of 40 units: • For 8 of the 40 samples, we did not receive any of the documentation requested. • For 1 of the 40 samples, we were unable to view biennial inspections being performed. • For 1 of the 40 samples, we were unable to view that HQS inspections were completed in accordance with the HCVP Admin plan. • For 27 of the 40 samples, we did not receive the completed letter from the DCHA specialists notifying the landlord and tenant in writing of the inspection. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: The Authority is not in compliance with federal regulations regarding HQS inspections. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition/Context: Exceptions noted in 35 of 40 units: • For 8 of the 40 samples, we did not receive any of the documentation requested. • For 1 of the 40 samples, we were unable to view biennial inspections being performed. • For 1 of the 40 samples, we were unable to view that HQS inspections were completed in accordance with the HCVP Admin plan. • For 27 of the 40 samples, we did not receive the completed letter from the DCHA specialists notifying the landlord and tenant in writing of the inspection. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: The Authority is not in compliance with federal regulations regarding HQS inspections. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-005 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that HQS inspections are completed in accordance with their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP created a dedicated phone line and email address to log and document inspections weekly. A designated staff member was assigned to review all inspection reports and findings, as well as to monitor the dedicated phone line and email address on a weekly basis. The OAC shall monitor this process on a monthly basis. Name of the contact person responsible for corrective action: Joseph Atkins. Planned completion date for corrective action plan: 6/30/24.

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2022-006
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

2022 – 006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition/Context: Exceptions noted in 25 of the 25 samples: • For 25 of the 25 files tested, we were not provided with the selection notice or letter notifying the tenant that they were selected and DCHA will determine eligibility for the program. • For 23 of 25 files tested, we were not provided with a copy of the signed voucher. • For 3 of the 25 files tested, the application or registration form was missing a housing specialist signature. • For 1 of the 25 files tested, we were not provided documentation of the applicant being admitted under a special program. • For 1 of the 25 files tested, we were not provided with supporting documentation for the preference indicated. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with new tenant selection requirements Effect: The Authority is not in compliance with federal regulations regarding the required new tenant selection requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained for new tenants. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition/Context: Exceptions noted in 25 of the 25 samples: • For 25 of the 25 files tested, we were not provided with the selection notice or letter notifying the tenant that they were selected and DCHA will determine eligibility for the program. • For 23 of 25 files tested, we were not provided with a copy of the signed voucher. • For 3 of the 25 files tested, the application or registration form was missing a housing specialist signature. • For 1 of the 25 files tested, we were not provided documentation of the applicant being admitted under a special program. • For 1 of the 25 files tested, we were not provided with supporting documentation for the preference indicated. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with new tenant selection requirements Effect: The Authority is not in compliance with federal regulations regarding the required new tenant selection requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained for new tenants. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-006 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained for new tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP is implementing a monthly quality control protocol to review new applicant files for completeness. A new Program Director was assigned to oversee this quality control process. The Program Director will also monitor the new tenant checklist which will be created to ensure that all new tenant documentation is accurately maintained. The OAC shall monitor and collaborate with the HCVP to ensure that the checklist is accurate and available for auditing. Name of the contact person responsible for corrective action: Starr Lane. Planned completion date for corrective action plan: 7/31/24.

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2022-007
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

2022 – 007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (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/Context: Exceptions noted in 19 of the 25 samples: • For 19 of the 25 files tested, we were not provided with the neighborhood standards report with the printed date, therefore we were unable to determine that DCHA determined the rent was reasonable prior to move-in in accordance with the administrative plan. • For 4 of the 20 samples, we were not provided with the HAP contract that was signed by a housing specialist/representative. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reasonable rent requirements. Effect: The Authority is not in compliance with federal regulations regarding the required reasonable rent requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that the rent to owner is reasonable in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (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/Context: Exceptions noted in 19 of the 25 samples: • For 19 of the 25 files tested, we were not provided with the neighborhood standards report with the printed date, therefore we were unable to determine that DCHA determined the rent was reasonable prior to move-in in accordance with the administrative plan. • For 4 of the 20 samples, we were not provided with the HAP contract that was signed by a housing specialist/representative. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reasonable rent requirements. Effect: The Authority is not in compliance with federal regulations regarding the required reasonable rent requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that the rent to owner is reasonable in accordance with their administrative plan. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-007 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the rent to owner is reasonable in accordance with their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP hired a third-party vendor, AffordableHousing.com, to conduct all rent reasonableness of all housing units that are presented for leasing, to ensure that the rent to owner is reasonable and in accordance with the administrative plan. The OAC shall monitor the compliance on a monthly basis. Name of the contact person responsible for corrective action: Ockeshia Pompey Planned completion date for corrective action plan: 7/31/24.

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2022-008
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

2022 – 008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition/Context: Exceptions noted in 18 of the 40 files tested: • For 2 of the 40 files tested, we were not provided with any of the documentation requested. • For 12 of the 40 files tested, we were not provided with the HAP Contract. • For 12 of the 40 files tested, we were not provided with the signed checklist. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with HAP contract and register requirements. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that files are maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition/Context: Exceptions noted in 18 of the 40 files tested: • For 2 of the 40 files tested, we were not provided with any of the documentation requested. • For 12 of the 40 files tested, we were not provided with the HAP Contract. • For 12 of the 40 files tested, we were not provided with the signed checklist. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with HAP contract and register requirements. Effect: The Authority is not in compliance with HAP requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that files are maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-008 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that files are maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP is implementing a monthly quality control protocol to review new applicant files for completeness. A new Program Director was assigned to oversee this quality control process. The Program Director will also monitor the new tenant checklist which will be created to ensure that all new tenant documentation is accurately maintained. The OAC shall monitor and collaborate with the HCVP to ensure that the checklist is accurate and available for auditing. Name of the contact person responsible for corrective action: Starr Lane Planned completion date for corrective action plan: 7/31/24.

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2022-009
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

2022 – 009 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: PHA's must submit timely GAAP-based unaudited and audited financial information electronically to HUD (see Section 13, Moving to Work (MTW) Agencies Reporting to FASS-PH, of Notice PIH-2012-21 (HA), issued May 10, 2012). Condition/Context: Exception noted for the timeliness of the submission. Questioned Costs: Unable to determine. Cause: The Authority did not submit their financial report to HUD in a timely manner. Effect: The Authority is not in compliance with financial reporting requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that financial reporting is completed and submitted timely. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 009 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: PHA's must submit timely GAAP-based unaudited and audited financial information electronically to HUD (see Section 13, Moving to Work (MTW) Agencies Reporting to FASS-PH, of Notice PIH-2012-21 (HA), issued May 10, 2012). Condition/Context: Exception noted for the timeliness of the submission. Questioned Costs: Unable to determine. Cause: The Authority did not submit their financial report to HUD in a timely manner. Effect: The Authority is not in compliance with financial reporting requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that financial reporting is completed and submitted timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-009 Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements controls to ensure that financial reporting is completed and submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: OFM leadership is updating the financial policies and procedures to include standard operating procedures (SOP) to accommodate the new Yardi financial software system. These SOPs will include a monthly closing checklist process that will be implemented to ensure that the financial reports are prepared and submitted timely. Name of the contact person responsible for corrective action: Heather Mueller. Planned completion date for corrective action plan: 09/30/2024.

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2022-010
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

2022 – 010 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Costs charged to the grant must be allowable in accordance with the criteria contained in 2 CFR Part 200, as applicable. Condition/Context: Exceptions noted in 1 of 40 allowable costs transactions: • For 1 payroll transaction selected, the Authority was unable to substantiate the rate of pay charged to the grant. Questioned Costs: $9,326 known; $1,636,013 projected. Cause: The Authority did not sufficiently monitor controls to ensure compliance with allowable activity requirements. Effect: The Authority is not in compliance with federal regulations related to allowable costs. Repeat Finding: No. Recommendation: We recommend management review the record-keeping practices to ensure that personnel documentation related to employee payrates can be easily accessed. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 010 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Costs charged to the grant must be allowable in accordance with the criteria contained in 2 CFR Part 200, as applicable. Condition/Context: Exceptions noted in 1 of 40 allowable costs transactions: • For 1 payroll transaction selected, the Authority was unable to substantiate the rate of pay charged to the grant. Questioned Costs: $9,326 known; $1,636,013 projected. Cause: The Authority did not sufficiently monitor controls to ensure compliance with allowable activity requirements. Effect: The Authority is not in compliance with federal regulations related to allowable costs. Repeat Finding: No. Recommendation: We recommend management review the record-keeping practices to ensure that personnel documentation related to employee payrates can be easily accessed. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-010 Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend management review the record-keeping practices to ensure that personnel documentation related to employee pay rates can be easily accessed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: In 2024 the Authority converted to the Kronos Pro payroll system, and is utilizing the software to its fullest capacity. This conversion will ensure that personnel documentation related to employee pay rates can be easily accessed and is audit-ready. The OFM shall include quality monitoring in its updated policies and procedures. The OAC shall oversee the quality monitoring process quarterly. Name of the contact person responsible for corrective action: Heather Mueller Planned completion date for corrective action plan: 9/30/2024.

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2022-011
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

2022 – 011 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA is required to submit this 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. 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/Context: Exceptions noted in 13 of the 40 samples. Exceptions included discrepancies between the HUD-50058 and the uploaded recertification and lack of support provided. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 011 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA is required to submit this 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. 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/Context: Exceptions noted in 13 of the 40 samples. Exceptions included discrepancies between the HUD-50058 and the uploaded recertification and lack of support provided. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-011 Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP shall recruit and hire a dedicated Data Analyst to oversee the PIC entries and to ensure that recertifications are uploaded in accordance with reporting requirements. The PIC uploads will be quality-controlled monthly by HCVP and quarterly by the Office of Audit and Compliance. The OAC will conduct monthly checks to ensure that the uploads are done to facilitate the required reporting. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24.

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2022-012
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

2022 – 012 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions noted in 14 of the 40 samples. We were not provided with support showing that a PIC submission was made for the recertification selected for testing. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with PIC reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: The finding is a repeat of finding 2021-006 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 012 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions noted in 14 of the 40 samples. We were not provided with support showing that a PIC submission was made for the recertification selected for testing. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with PIC reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: The finding is a repeat of finding 2021-006 in the prior audit period. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-012 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP shall recruit and hire a dedicated Data Analyst to oversee the PIC entries and to ensure that recertifications are uploaded in accordance with reporting requirements. The PIC uploads will be quality-controlled monthly by HCVP and quarterly by the OAC. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24.

Prior Finding References

2021-006

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2022-013
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

2022 – 013 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised (24 CFR section 982.517). Condition/Context: DCHA did not review utility rate data for each utility category during the fiscal year. Questioned Costs: Unable to determine. Cause: The Authority did not maintain an update utility allowance schedule. Effect: The Authority is not in compliance with federal regulations regarding the requirement of maintaining an updated utility allowance schedule. Repeat Finding: No Recommendation: We recommend the Authority implements controls to ensure that the utility rate data for each utility category is reviewed each year to ensure that an up-to-date utility allowance schedule is maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

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2022 – 013 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2022 Award Period: October 1, 2021 – September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised (24 CFR section 982.517). Condition/Context: DCHA did not review utility rate data for each utility category during the fiscal year. Questioned Costs: Unable to determine. Cause: The Authority did not maintain an update utility allowance schedule. Effect: The Authority is not in compliance with federal regulations regarding the requirement of maintaining an updated utility allowance schedule. Repeat Finding: No Recommendation: We recommend the Authority implements controls to ensure that the utility rate data for each utility category is reviewed each year to ensure that an up-to-date utility allowance schedule is maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-013 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the utility rate data for each utility category is reviewed each year to ensure that an up-to-date utility allowance schedule is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP shall hire a third-party vendor to conduct the utility allowance schedule. Allen Fox Consulting will be hired to begin the utility allowance projections in July 2024. The OAC will monitor the process to ensure that the contractor is hired by the specified date and that they start maintaining an up-to-date utility allowance schedule. Name of the contact person responsible for corrective action: Anissa Jones. Planned completion date for corrective action plan: 7/31/24.

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FY 2021-09-30

$337,562,266 federal awards expended

FAC accepted this audit on December 21, 2023 — management decision was due June 21, 2024.

2021-002
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) Criteria or specific requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104- 134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-HCV (40) and MTW-LRPH (40) found exceptions in 20 of the 40 MTW-LRPH files tested and 5 of the 40 MTW-HCV files tested. The following MTW-LRPH exceptions were noted:  For 5 of 40 files tested, we were unable to observe any of the request backup (recertificaiton printout, income support, checklists, etc.)  For 5 of 40 files tested, support was provided, however, CLA did not observe a 50058 with an effective date prior to, and effective for, the rent payment pulled from rent roll.  For 2 of the 40 files tested, CLA was unable to recalculate annual family income listed in the tenant file to the backup support provided. We did not observe backing support to recalculate the annual income listed on the tested 50058.  For 1 of 40 files tested, CLA did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis.  For 10 of 40 tenant files tested, we did not observe a recertification checklist or the signed Application for Applied Occupancy completed by the specialist. The following MTW-HCV exceptions were noted:  For 4 of 40 MTW-HCVP samples, we were unable to recalculate the income total listed on the HUD-50058 based on the backing support provided.  For 4 of 40 MTW-HCVP samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature (documenting performance of a key internal control) The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2020-001 in the prior audit period. The prior year's finding was a significant deficiency in internal control over compliance. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) Criteria or specific requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104- 134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-HCV (40) and MTW-LRPH (40) found exceptions in 20 of the 40 MTW-LRPH files tested and 5 of the 40 MTW-HCV files tested. The following MTW-LRPH exceptions were noted:  For 5 of 40 files tested, we were unable to observe any of the request backup (recertificaiton printout, income support, checklists, etc.)  For 5 of 40 files tested, support was provided, however, CLA did not observe a 50058 with an effective date prior to, and effective for, the rent payment pulled from rent roll.  For 2 of the 40 files tested, CLA was unable to recalculate annual family income listed in the tenant file to the backup support provided. We did not observe backing support to recalculate the annual income listed on the tested 50058.  For 1 of 40 files tested, CLA did not observe support in the tenant file indicated that family income and composition were examined on a biennial basis.  For 10 of 40 tenant files tested, we did not observe a recertification checklist or the signed Application for Applied Occupancy completed by the specialist. The following MTW-HCV exceptions were noted:  For 4 of 40 MTW-HCVP samples, we were unable to recalculate the income total listed on the HUD-50058 based on the backing support provided.  For 4 of 40 MTW-HCVP samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature (documenting performance of a key internal control) The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: The finding is a repeat of finding 2020-001 in the prior audit period. The prior year's finding was a significant deficiency in internal control over compliance. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken/planned in response to finding: HCVP will continue to utilize quality control measures to conduct quality control reviews of 100% of eligibility determinations to ensure documentation is complete, accurate and available for audit. HCVP has coordinated staff trainings for file protocols to be completed by May 30, 2023. Name of the contact person responsible for corrective action: Anissa Jones Planned completion date for corrective action plan: May 31, 2023 and on a periodic basis

Prior Finding References

2020-001

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2021-003
Eligibility
MATERIAL WEAKNESSMODIFIED OPINION

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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 section 982.516). Condition/Context: Exceptions noted in 4 out of 40 NON-MTW HCVP files tested:  For 3 of 40, we were unable to recalculate the income total listed on the HUD-50058 based on the backing support provided.  For 1 of 40 samples, we did not observe documentation showing the head of household was the parent or legal guardian to a dependent for which an allowance was granted.  For 1 of 40 samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature (documenting performance of a key internal control). The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: No. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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 section 982.516). Condition/Context: Exceptions noted in 4 out of 40 NON-MTW HCVP files tested:  For 3 of 40, we were unable to recalculate the income total listed on the HUD-50058 based on the backing support provided.  For 1 of 40 samples, we did not observe documentation showing the head of household was the parent or legal guardian to a dependent for which an allowance was granted.  For 1 of 40 samples, we did not observe a recertification checklist, or a substitute application, showing a specialist's signature (documenting performance of a key internal control). The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using incorrect information in the rent calculation. Tenant recertifications were not shown to be performed on a timely basis. Repeat Finding: No. Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend that DCHA staff review the controls in place to ensure that required eligibility determination documentation is complete, accurate, and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken/planned in response to finding: HCVP will continue to utilize quality control measures to conduct quality control reviews of 100% of eligibility determinations to ensure documentation is complete, accurate and available for audit. HCVP has coordinated staff trainings for file protocols to be completed by May 30, 2023. Name of the contact person responsible for corrective action: Anissa Jones Planned completion date for corrective action plan: May 31, 2023 and on a periodic basis

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2021-004
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition/Context: Exceptions noted in 3 of 15 failed inspections. Reinspections were not performed within the required timeframe. This resulted in the Authority failing to properly abate the unit. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) Criteria or specific requirement: For units under HAP contract that fail to meet HQS, the Authority must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified Authority approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition/Context: Exceptions noted in 3 of 15 failed inspections. Reinspections were not performed within the required timeframe. This resulted in the Authority failing to properly abate the unit. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not reinspect or abate units timely. Effect: The Authority is not in compliance with HQS enforcement requirements. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken/planned in response to finding: HCVP has updated the standard operation procedures for clarifying step-by-step instructions needed to enforce HQS deficiencies and have trained inspection staff on the procedures. HCVP is working with our system of records to develop the proper reports and tools needed to effectively track landlord/unit compliance within the required timeframes. Name of the contact person responsible for corrective action: Anissa Jones Planned completion date for corrective action plan: May 31, 2023

About Special Tests and Provisions →
2021-005
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions were noted in 6 of 40 recertifications: Exceptions were noted in 3 of the 20 MTW-LRPH samples. HUD-50058’s were created, modified and approved; however, they were never submitted into PIC, as the files were excluded by the specialist. Exceptions were noted in 3 of the 20 MTW-HCV samples. The recertifications were not uploaded to PIC. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions were noted in 6 of 40 recertifications: Exceptions were noted in 3 of the 20 MTW-LRPH samples. HUD-50058’s were created, modified and approved; however, they were never submitted into PIC, as the files were excluded by the specialist. Exceptions were noted in 3 of the 20 MTW-HCV samples. The recertifications were not uploaded to PIC. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken/planned in response to finding: HCVP continues to transmit all 50058 transactions to PIC on a weekly basis and review PIC error reports for corrections needed. Any identified errors are assigned to specific staff for correction within 5 business days. The PIC coordinator will confirm corrections are submitted and accepted in PIC. A monthly report will be provided to the Senior VP summarizing the number of transmissions, errors, and status of corrections. Name of the contact person responsible for corrective action: Khaliah Payne Planned completion date for corrective action plan: Ongoing until all PIC errors are addressed/resolved as needed.

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2021-006
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions noted in 9 of the 40 samples. The recertifications were not uploaded to PIC. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: DC001VO - 2021 Award Period: October 1, 2020 – September 30, 2021 Type of Finding:  Material Weakness in Internal Control over Compliance  Material Noncompliance (Modified Opinion) 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. 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/Context: Exceptions noted in 9 of the 40 samples. The recertifications were not uploaded to PIC. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with reporting requirements Effect: The Authority is not in compliance with federal regulations regarding the required submission of all recertifications to the PIC system. Repeat Finding: No. Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken/planned in response to finding: HCVP continues to transmit all 50058 transactions to PIC on a weekly basis and review PIC error reports for corrections needed. Any identified errors are assigned to specific staff for correction within 5 business days. The PIC coordinator will confirm corrections are submitted and accepted in PIC. A monthly report will be provided to the Senior VP summarizing the number of transmissions, errors, and status of corrections. Name of the contact person responsible for corrective action: Khaliah Payne Planned completion date for corrective action plan: Ongoing until all PIC errors are addressed/resolved as needed.

About Reporting →

FY 2020-09-30

$334,956,865 federal awards expended

FAC accepted this audit on December 28, 2021 — management decision was due June 28, 2022.

2020-001
Eligibility
SIGNIFICANT DEFICIENCYREPEATOTHER MATTERS

2020 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Moving to Work Demonstration CFDA Number: 14.881 Award Period: October 1, 2019 through September 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Beneficiaries must be ?low-income families,? as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-HCV (40) and MTW LRPH (40) found exceptions in 2 of the 40 MTW-LRPH files tested. The following exceptions were noted: ? One of 40 MTW-LRPH files did not have documentation to support income that was included in the recertification tested. ? One of 40 MTW-LRPH files selected failed to document the completion of a timely UPCS inspection. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility and inspection requirements. Effect: The Authority is not in compliance with requirements set forth by HUD and Uniform Guidance. Tenant rent was calculated utilizing unsupported income. Units may not meet housing quality standards established by HUD. Repeat Finding: The finding is a repeat of finding 2019-001 in the prior audit period. The prior year's finding was a material weakness in internal control over compliance; as such, the finding was partially corrected. Recommendation: We recommend that DCHA staff review the controls in place to ensure that income is properly calculated based on the information maintained within the tenant file and required timely inspections are performed. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

2020 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Moving to Work Demonstration CFDA Number: 14.881 Award Period: October 1, 2019 through September 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Beneficiaries must be ?low-income families,? as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-HCV (40) and MTW LRPH (40) found exceptions in 2 of the 40 MTW-LRPH files tested. The following exceptions were noted: ? One of 40 MTW-LRPH files did not have documentation to support income that was included in the recertification tested. ? One of 40 MTW-LRPH files selected failed to document the completion of a timely UPCS inspection. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility and inspection requirements. Effect: The Authority is not in compliance with requirements set forth by HUD and Uniform Guidance. Tenant rent was calculated utilizing unsupported income. Units may not meet housing quality standards established by HUD. Repeat Finding: The finding is a repeat of finding 2019-001 in the prior audit period. The prior year's finding was a material weakness in internal control over compliance; as such, the finding was partially corrected. Recommendation: We recommend that DCHA staff review the controls in place to ensure that income is properly calculated based on the information maintained within the tenant file and required timely inspections are performed. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Housing and Urban Development The District of Columbia Housing Authority respectfully submits the following corrective action plan for the year ended September 30, 2020. Audit period: October 1, 2019 ? September 30, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2020-001 Moving to Work Demonstration Program ? CFDA No. 14.881 Recommendation: The auditors recommend that DCHA staff review the controls in place to ensure that income is properly calculated based on the information maintained within the tenant file and required timely inspections are performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Recertifications ? Retention of Income Verification Property Management Operations (PMO) is no longer contracting with third-party agencies to manage its traditional public housing unit inventory. PMO?s Housing Managers (HMs) and Housing Management Assistants (HMAs) will be charged with performing all elements of the public housing recertifications process. PMO?s HMs and HMAs will be required to implement the utilization of the recertification checklist as a means of internal controls ensuring that all documents were obtained during recertification, including income verifications. The documents, including income verifications, retrieved during the public housing resident?s interim; biennial, and triennial recertification examination will be electronically stored in the Yardi system. Monthly, PMO?s Area Managers will be responsible for conducting quality control reviews of 10% of all public housing recertifications conducted within their portfolio ensuring that the recertification checklist was used and signed-off on by the HM/HMA and that the income verifications are properly retained in the public housing resident?s electronic Yardi file. Name of the contact person responsible for corrective action: Brandy Lynch, Deputy Director PMO Planned completion date for corrective action plan: First Quarter of FY 2022 Timely Uniform Physical Condition Standards Inspections (UPCS): PMO?s Facilities Maintenance team is charged with ensuring that the UPCS inspections are conducted in each public housing unit, annually, beginning in October and to be completed by July. Facilities Maintenance staff at each site under the direction of PMO?s Regional Maintenance Supervisors (RMS) will conduct a set number of unit inspections weekly, based on the number of units at each property to be completed monthly over a ten (10) month period. Every month, PMO?s Regional Maintenance Supervisors (RMS) will be required to pull the missed UPCS inspections report in Yardi as an internal control mechanism, and any units identified on the said report will be immediately re-scheduled for its UPCS inspection. Quarterly, Regional Maintenance Supervisors will conduct a QC inspection of 10% of all completed UPCS inspections to ensure that they were completed following the guidelines outlined in the SOP. With the integration of the new UPCS inspection module in Yardi, training for the staff will be provided through ITD. As another control mechanism, during housekeeping inspection, property managers and housing manager assistants will pull copies of completed UPCS inspections to further ensure that deficiencies were abated. Name of the contact person responsible for corrective action: Douglas Moody, Chief of Facilities. Planned completion date for corrective action plan: First Quarter FY 2022 Note: The Office of Audit & Compliance will complete and document Quality Control checks quarterly of PMO?s implemented corrective action plans to begin at the end of the First Quarter of FY 2022.

Prior Finding References

2019-001

About Eligibility →

FY 2019-09-30

LOW-RISK AUDITEE$328,689,937 federal awards expended

FAC accepted this audit on June 18, 2020 — management decision was due December 18, 2020.

2019-001
Eligibility
MATERIAL WEAKNESSREPEATOTHER MATTERS

Criteria: Beneficiaries must be ?low-income families,? as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-HCV (40) and MTW-LRPH (40) found exceptions in 9 of the 40 MTW-HCV files and 12 of the 40 MTW-LRPH files tested. The following exceptions were noted: ? One of 40 MTW-HCV files selected did not have proper income support included in the recertification. ? One of 40 MTW-HCV files was not recertified timely. ? Five of 40 MTW-HCV files selected failed to document the completion of a timely HQS inspection. ? Two of 40 MTW-HCV files did not include a quality control checklist (internal control over compliance). ? One of 40 MTW-LRPH files had incorrectly calculated annual income that was utilized in the recertifcation. ? One of 40 MTW-LRPH files was not recertified timely. ? Ten of 40 MTW-LRPH files selected failed to document the completion of a timely UPCS inspection. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility and inspection requirements. Effect: The Authority is not in compliance with requirements set forth by HUD. Tenant rent and related HAP was miscalculated. Recertifications were not performed timely. Units may not meet housing quality standards established by HUD. Repeat Finding: Yes, finding 2018-001 Recommendation: We recommend that DCHA staff review the controls in place to ensure that income is properly calculated based on the information maintained within the tenant file, recertifications are performed timely, and required timely inspections are performed. Views of Responsible Officials: There is no disagreement with the audit finding.

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Full finding narrative

Criteria: Beneficiaries must be ?low-income families,? as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). The Authority must ensure that housing assisted under the demonstration meets housing quality standards established or approved by HUD (Section 204(c)(3)(E) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition/Context: A sample of 80 tenant files tested for eligibility over MTW-HCV (40) and MTW-LRPH (40) found exceptions in 9 of the 40 MTW-HCV files and 12 of the 40 MTW-LRPH files tested. The following exceptions were noted: ? One of 40 MTW-HCV files selected did not have proper income support included in the recertification. ? One of 40 MTW-HCV files was not recertified timely. ? Five of 40 MTW-HCV files selected failed to document the completion of a timely HQS inspection. ? Two of 40 MTW-HCV files did not include a quality control checklist (internal control over compliance). ? One of 40 MTW-LRPH files had incorrectly calculated annual income that was utilized in the recertifcation. ? One of 40 MTW-LRPH files was not recertified timely. ? Ten of 40 MTW-LRPH files selected failed to document the completion of a timely UPCS inspection. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not sufficiently monitor controls to ensure compliance with eligibility and inspection requirements. Effect: The Authority is not in compliance with requirements set forth by HUD. Tenant rent and related HAP was miscalculated. Recertifications were not performed timely. Units may not meet housing quality standards established by HUD. Repeat Finding: Yes, finding 2018-001 Recommendation: We recommend that DCHA staff review the controls in place to ensure that income is properly calculated based on the information maintained within the tenant file, recertifications are performed timely, and required timely inspections are performed. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2019-001 Moving to Work Demonstration Program ? CFDA No. 14.881 Recommendation: The auditors recommend that DCHA staff review the controls in place to ensure that income is properly calculated based on the information maintained within the tenant file, recertifications are performed timely, and required timely inspections are performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: DCHA?s HCVP is implementing a two-pronged internal controls methodology to ensure that income is properly calculated based on the information maintained within participants? files. HCVP also instituting a process to ensure that recertifications are timely performed and that HQS inspections are conducted, timely. Income Calculations: The first prong of the two-pronged internal controls approach includes the Housing Programs Manager (HPM) requiring direct reports to randomly select 10% of recertifications conducted weekly and utilizing the Housing Program Specialist (HPS) quality controls checklist to confirm that participants? income is calculated accurately. Any errors uncovered will be corrected and the HPS will receive one-on-one coaching relating to the miscalculation. The second prong of the two-pronged approach requires HCVP?s Quality Assurance (QA) division to use the quality control tool and perform internal controls/file reviews of 10% of the overall recertification action types processed during the previous month. These files will also be randomly selected. If errors are found, the QA Manager will consult with the HPM, ensuring that the errors are corrected and guidance is provided to the Housing Programs staff. Additionally, under this prong, the Housing Programs staff will be required to attend quarterly training provided by external consultants and/or internal training department. Timely Recertifications and HQS Inspections: HCVP?s QA division is charged with routinely running preliminary inspections and recertification reports to identify any missed inspections or missed recertifications. The Inspections Manager and the Housing Programs Manager will use the reports as an internal control mechanism to ensure that any units and households identified are immediately scheduled for HQS inspections or scheduled for recertification interviews. Name of the contact person responsible for corrective action: Carolyn Kornegay Punter Planned completion date for corrective action plan: Fourth Quarter of FY2020 Timely LRPH Recertifications: Currently, DCHA follows the HUD protocol and issues three reminder notices to residents (90, 60, and 30 days before its due date). The internal recertification process will be reviewed by Area Managers ensuring the Housing Managers and Housing Management Assistants are collecting and processing documents in an accurate, timely manner. Those that are found to be deficient in this area will be required to take mandatory training classes to elevate skill sets. We will also continue ongoing training with all staff on our current tenant-based software for the remainder of 2020. Name of the contact person responsible for corrective action: Brandy Lynch, Deputy Director of Property Management Operations Planned completion date for the corrective action plan: Fourth Quarter of CY 2020 Timely UPCS Inspections: The agency has moved to a new more efficient tenant-based system. This system has an inspection module that will generate reports to document current and past due inspections. We are working on embedding within the module ticklers to notify Housing Managers, Foremen, and Regional Supervisors of missed inspections. We hope to have this module in place by June 2020. Regional Supervisors will pull and QC 10% of the reports for each property to ensure missed or late inspections are re-scheduled and completed. They will also ensure completed inspections are documented properly and work orders are created to address any deficiencies. All staff will undergo continued education and training on UPCS protocol and the current software to ensure efficiency in future inspections. Name of the contact person responsible for corrective action: Douglas Moody, Chief of Facilities Maintenance Planned completion date for corrective action plan: Fourth Quarter of CY 2020

Prior Finding References

2018-001

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2019-002
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

Criteria: 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/Context: A sample of 40 tenant files tested for eligibility found exceptions in 2 of the 40 files. The files did not include documentation that the tenant was homeless upon entry into the program. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not maintain permanent file documentation within the tenant's file to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with eligibility requirements set forth by HUD. Repeat Finding: No Recommendation: We recommend that DCHA staff review their policies and procedures for maintaining permanent file documentation within the tenant?s file. Views of Responsible Officials: There is no disagreement with the audit finding.

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Criteria: 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/Context: A sample of 40 tenant files tested for eligibility found exceptions in 2 of the 40 files. The files did not include documentation that the tenant was homeless upon entry into the program. The sample was statistically valid. Questioned Costs: Unable to determine. Cause: The Authority did not maintain permanent file documentation within the tenant's file to ensure compliance with eligibility requirements. Effect: The Authority is not in compliance with eligibility requirements set forth by HUD. Repeat Finding: No Recommendation: We recommend that DCHA staff review their policies and procedures for maintaining permanent file documentation within the tenant?s file. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

2019-002 Section 8 Project Based Cluster (Single Room Occupancy) ? CFDA No. 14.249 Recommendation: The auditors recommend that DCHA staff review their policies and procedures for maintaining permanent file documentation within the tenant?s file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: DCHA?s HCVP is implementing the actions listed below to ensure that HCVP?s Housing Programs employees adhere to DCHA?s records retention policies and procedures relating to participants? permanent records. In general, HCVP staff will undergo training related to DCHA?s policies and procedures for maintaining permanent records in participants? electronic files. More specifically, HCVP is implementing a three-year plan to ensure that all files are reviewed to determine whether they contain complete permanent file documentation. Recertifications are conducted bi-annually or tri-annually. During the recertification process, the HPS will review the permanent files, ensuring that each family members? permanent documents have been maintained and if it is discovered that the permanent records are missing, the HPS will: (1) collected the documents from the participant and upload those documents to DCHA?s electronic platform that is used to retain participants? records; or (2) if the documentation cannot be obtained from the participant or a third party due to the time lapsed, the HPS will draft and upload a memo documenting such to the participant?s electronic file. Lastly, HCVP?s Quality Assurance (QA) division will use the quality control tool and perform internal controls/file reviews of 10% of the overall recertification action types processed during the previous month to ensure that the permanent documents are part of the participant?s file. If permanent records are missing, HCVP?s QA division will verify that the required memo is attached to the electronic file. If it is determined that the memo is also missing, the HPM will be alerted, the record will be corrected and the HPS will receive one-on-one coaching. Name of the contact person responsible for corrective action: Carolyn Kornegay Punter Planned completion date for corrective action plan: Fourth Quarter of CY2023

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FY 2018-09-30

LOW-RISK AUDITEE$296,839,400 federal awards expended

FAC accepted this audit on June 9, 2019 — management decision was due December 9, 2019.

2018-001
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-002
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-09-30

LOW-RISK AUDITEE$281,533,711 federal awards expended

FAC accepted this audit on May 22, 2018 — management decision was due November 22, 2018.

2017-001
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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