Charlottesville Redevelopment and Housing Authority

Section 8 Housing Choice Vouchers Program ALN#14.871 Eligibility: Tenant ComplianceCONDITION: During the compliance audit of the Authority’s Housing Choice Voucher program we noted two tenants whose income was not verified during annual recertifications with current EIV Income Reports, as required by HUD regulations. CRITERIA:Tenants of the Housing Choice Voucher program are required to be recertified annually and on the interim basis in accordance with HUD regulations. Recertification guidelines require use of the Enterprise Income Verification (EIV) System to verify tenants’ reported incomes during annual recertifications. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: Of 40 tenant files examined, 2 files did not contain documentation that the tenants’ reported income was verified with current EIV Income Reports during annual recertifications. EFFECT: The Housing Authority could be renting to tenants who are not paying the appropriate amount of rent per program regulations. CAUSE: The overall cause was a lack of effective management oversight and quality control over this program. RECOMMENDATION: The Housing Authority should implement greater oversight over Housing Choice Voucher tenant compliance and train employees on procedures mandated by HUD regarding tenant income verification and annual recertification.

Finding No. 2023-001- Section 8 Housing Choice Vouchers Program CFDA#14.871 Eligibility: Tenant Compliance The agency acknowledges that all tenants are required to have their income verified with current EIV Income Reports, as required by HUD regulations. Due to new staff and management changes, all staff did not always have access to EIV. Going forward management will ensure that all staff members have appropriate access to EIV and income verification methods. The PHA will also implement greater oversight over HCV compliance and train employees on procedures mandated by HUD regarding tenant income verification and annual recertification. Planned Implementation Date of Corrective Action: 12/18/2023 Person responsible for corrective action plan implementation: Interim Housing Choice Voucher Program Manager, Janice Spellman and staff. Best Regards, Navonya Thomas Director of Property Management Charlottesville Redevelopment & Housing Authority.

ALN#14.871 Special Tests and Provisions: HQS Inspections CONDITION: The Authority failed to document annual Housing Quality Standards (HQS) inspections in accordance with its Administrative Plan and HUD regulations. CRITERIA: PHAs are required to inspect units leased to Housing Choice Voucher participants at least annually and prepare unit inspection reports in accordance with 21 CFR 982.158(d). QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: 40 HAP contract files from a statistically valid sample were examined for compliance with annual HQS inspection requirements. Of the files examined, 1 file did not contain a current annual inspection report. EFFECT: The Authority is not in compliance with federal regulations regarding HQS inspections and documentation. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the inspection process of the Housing Choice Voucher program to ensure that annual inspections are completed and documented at least annually as required.

Finding No. 2023-003- Section 8 Housing Choice Vouchers Program CFDA#14.871 Special Tests and Provisions The agency acknowledges that we are required to inspect units leased to Housing Choice Voucher participants at least annually and prepare the unit inspection reports in accordance with 21 CFR 982.158 (d). Of the 40 HAP contract files used in the sample, we acknowledge that one file was missing an HQS inspection. In order to correct this issue going forward, the PHA will implement better quality control over the inspection process of the Housing Choice Voucher program to ensure that no annual inspections are missed and that all are completed and documented at least annually as required. Plan Implementation Date of Corrective Action: 12/18/2023 Person responsible for corrective action plan implementation: Janice Spellman, Interim HCV Program Manager and staff. Best Regards, Navonya Thomas Director of Property Management Charlottesville Redevelopment and Housing Authority

Finding No. 2021-001 CFDA No.14.871 Special Tests and Provisions: Rent Reasonableness (Repeat from 2018,2019, and 2020) CONDITION: CRITERIA: QUESTIONED COSTS: CONTEXT: EFFECT: The Authority failed to employ an effective methodology to determine and document the reasonableness of rents charged by owners to Housing Choice Voucher participants in accordance with its written Administrative Plan and HUD regulations. PHAs are required to determine whether rents charged by owners to Housing Choice Voucher program participants are reasonable, with respect to comparable unassisted units; prior to entering into HAP contracts; when there is a 5 percent or more decrease in the FMR within 60 days of the HAP contract anniversary; and prior to approving any subsequent rent increases in accordance with 24 CFR 982.507. The amount of questioned costs could not be determined. During audit fieldwork, 40 HAP contract files from a statistically valid sample were examined for compliance with rent reasonableness determination criteria. Of the 40 files examined, three files did not contain evidence to support sufficient steps had been taken to determine that HAP contract rents paid to owners were reasonable. Failure to determine rent reasonableness provides no assurance that HUD funds are being used efficiently as it may lead to the approval of rents that are too high. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the Housing Choice Voucher program and provide additional training to staff on determining rent reasonableness in accordance with CRHA's Administrative Plan and HUD regulations.

Finding No. 2021-001 CFDA No. 14.871 Special Tests and Provisions {Repeat from 2018, 2019 and 2020) The Authority concurs that there were deficiencies in the rent reasonableness process. Due to turnover in executive and management staff this issue wasn't properly addressed. The PHA did not complete and verify all rent reasonableness studies and comparisons were completed for all units in the voucher po1ifolio. The PHA will continue to address this issue through the recertification and initial certification process and correct any prior deficiencies on a going forward basis. Planned Implementation Date of Corrective Action Plan: March 31, 2022 Person Responsible for Corrective Action Plan: Consuela Knight, Housing Choice Voucher Manager (434) 326-4672.

2020-001

Finding No. 2021-002 CFDA No. 14.871 - Eligibility (Repeat from 2019 and 2020) 53 CONDITION: The Authority failed to complete annual recertifications in accordance with its Administrative Plan and HUD regulations. CRITERIA: PHAs are required to reexamine family income and composition at least once every 12 months and calculate tenant rents and housing assistance payments in accordance with 24 CFR 982.516. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: During audit fieldwork, 40 HAP contract files and 40 Public Housing Files, each from statistically valid samples were examined for compliance with annual tenant recertification requirements. Of the 40 HAP files examined, four files contained inaccurate calculations of tenant rents and housing assistance payments reported on HUD Form-50058. EFFECT: Failure to accurately calculate tenant rent and housing assistance payments as required could lead to inappropriate tenant rent and housing assistance payment charges. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the Housing Choice Voucher program to ensure that annual recertifications include accurate calculations of tenant rent and housing assistance payments reported on HUD Form-50058.

Finding No. 2021-001 CFDA No. 14.871 Special Tests and Provisions {Repeat from 2018, 2019 and 2020) The Authority concurs that there were deficiencies in the rent reasonableness process. Due to turnover in executive and management staff this issue wasn't properly addressed. The PHA did not complete and verify all rent reasonableness studies and comparisons were completed for all units in the voucher po1ifolio. The PHA will continue to address this issue through the recertification and initial certification process and correct any prior deficiencies on a going forward basis. Planned Implementation Date of Corrective Action Plan: March 31, 2022 Person Responsible for Corrective Action Plan: Consuela Knight, Housing Choice Voucher Manager (434) 326-4672.

2020-002

Finding No. 2021-003 CFDA No. 14.871 - Special Tests and Provisions: HQS Enforcement 54 CONDITION: The Authority failed to document enforcement of Housing Quality Standards (HQS) in accordance with its Administrative Plan and HUD regulations. CRITERIA: For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: During audit fieldwork, 40 HAP contract files from independent statistically valid samples were examined for compliance with HQS enforcement requirements. Of the 40 HAP files examined, one file did not contain evidence to support that HQS inspection failures were either corrected or that the unit was abated for not meeting HQS as required. EFFECT: The Authority is not in compliance with federal regulations regarding HQS enforcement. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION; The Authority should implement greater oversight over the HQS enforcement process in the Housing Choice Voucher program to ensure that HQS inspection failures are corrected or, if necessary, units are abated for failure to meet HQS.

Finding No. 2021-003 CFDA No. 14.871 Special Tests and Provisions The Authority concurs that there were deficiencies in the HCVP voucher annual Housing Quality Standards (HQS) inspection process. Due to turnover in executive and management staff this issue wasn't properly completed or reviewed during the fiscal year. All HQS inspections for all units in the voucher portfolio were not completed in a timely fashion. The PHA will continue to address this issue through the next fiscal year and do quality control reviews of prior inspections to insure all have been completed for fiscal year 2020. Planned Implementation Date of Corrective Action Plan: March 31, 2022 Person Responsible for Corrective Action Plan: Consuela Knight, Housing Choice Voucher Manager (434) 326-4672.

2020-003

Finding No. 2020-001 CFDA No. 14.871 Special Tests and Provisions (Repeat from 2018 and 2019) CONDITION: CRITERIA: QUESTIONED COSTS: CONTEXT: EFFECT: CAUSE: The Authority failed to employ an effective methodology to determine and document the reasonableness of rents charged by owners to Housing Choice Voucher participants in accordance with its written Administrative Plan and HUD regulations. PHAs are required to determine whether rents charged by owners to Housing Choice Voucher program participants are reasonable, with respect to comparable unassisted units; prior to entering into HAP contracts; when there is a 5 percent or more decrease in the FMR within 60 days of the HAP contract anniversary; and prior to approving any subsequent rent increases in accordance with 24 CFR 982.507. The amount of questioned costs could not be determined. During audit fieldwork, 40 HAP contract files from a statistically valid sample were examined for compliance with rent reasonableness determination criteria. Of the 40 files examined, 15 files did not contain evidence to support that sufficient steps had been taken to determine that HAP contract rents paid to owners were reasonable. Failure to determine rent reasonableness provides no assurance that HUD funds are being used efficiently as it may lead to the approval of rents that are too high. The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the Housing Choice Voucher program and provide additional training to staff on determining rent reasonableness in accordance with CRHA's Administrative Plan and HUD regulations.

Finding No. 2020-001 CFDA No. 14.871 Special Tests and Provisions {Repeat from 2018) The Authority concurs that there were deficiencies in the rent reasonableness process. Due to turnover in executive and management staff this issue wasn't properly addressed. The PHA did not complete and verify all rent reasonableness studies and comparisons were completed for all units in the voucher portfolio. The PHA will continue to address this issue through the recertification and initial certification process and correct any prior deficiencies on a going forward basis. The PHA has purchased the Rent Reasonableness software and begin implementing it in October 2020. Planned Implementation Date of Corrective Action Plan: March 31, 2021 Person Responsible for Corrective Action Plan: Melinda Hite, Housing Manager (434) 326-4672.

2019-001

Finding No. 2020-002 CFDA Nos. 14.850 and 14.871 Eligibility (Repeat from 2019) CONDITION: The Authority failed to complete annual recertifications in accordance with its Administrative Plan and HUD regulations. CRITERIA: PHAs are required to reexamine family income and composition at least once every 12 months and calculate tenant rents and housing assistance payments in accordance with 24 CFR 982.516. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: During audit fieldwork, 40 HAP contract files and 40 Public Housing Files, each from statistically valid samples were examined for compliance with annual tenant recertification requirements. Of the 40 HAP files examined, five files contained inaccurate calculations of tenant rents and housing assistance payments reported on HUD Form-50058. Of the 40 Public Housing files, fifteen did not contain an EIV. EFFECT: Failure to accurately calculate tenant rent and housing assistance payments as required could lead to inappropriate tenant rent and housing assistance payment charges. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the Housing Choice Voucher program to ensure that annual recertifications include accurate calculations of tenant rent and housing assistance payments reported on HUD Form-50058, and ensure EIVs are filed for public housing.

Finding No. 2020-002 CFDA No.14.871 Eligibility The Authority concurs that there were deficiencies in the HCVP voucher annual recertification process. Due to turnover in executive and management staff this issue wasn't properly addressed. Annual recertifications and calculation of rent for all units in the voucher portfolio were not completed in a timely fashion or accurately. The PHA will continue to address this issue through the recertification and initial certification process and correct any prior deficiencies on a going forward basis. Planned Implementation Date of Correction Action Plan: March 31,2021 Person Responsible for Corrective Action Plan: Melinda Hite, Housing Manager (434) 326-4672.

2019-002

Finding No. 2020-003 CFDA Nos. 14.850 and 14.871 Special Tests and Provisions (Repeatfrom 2019) CONDITION: The Authority failed to document annual Housing Quality Standards (HQS) inspections in accordance with its Administrative Plan and HUD regulations. CRITERIA: PHAs are required to inspect units leased to Housing Choice Voucher and Public Housing program participants at least annually and prepare unit inspection reports in accordance with 21 CFR 982.158(d). QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: During audit fieldwork, 40 HAP contract files and 40 Public Housing files each from independent statistically valid samples were examined for compliance with annual HQS inspection requirements. Of the 40 HAP files examined, 17 files did not contain current annual inspection reports. Of the 40 Public Housing files examined, 27 did not contain current annual inspection reports. EFFECT: The Authority is not in compliance with federal regulations regarding HQS inspections and documentation. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the inspection process in both the Housing Choice Voucher and Public Housing programs to ensure that annual inspections are completed and documented at least annually as required.

Finding No. 2020-003 CFDA No.14.871 Special Tests and Provisions The Authority concurs that there were deficiencies in the HCVP voucher annual Housing Quality Standards (HQS) inspection process. Due to turnover in executive and management staff this issue wasn't properly completed or reviewed during the fiscal year. All HQS inspections for all units in the voucher portfolio were not completed in a timely fashion. The PHA will continue to address this issue through the next fiscal year and do quality control reviews of prior inspections to insure all have been completed for fiscal year 2020. The PHA now has 4 certified HQS Inspectors and is actively completing HQS inspections. Planned Implementation Date of Correction Action Plan: March 31, 2021 Person Responsible for Corrective Action Plan: Melinda Hite, Housing Manager (434) 326-4672.

2019-003

Finding No. 2019-001 CFDA No. 14.871 Special Tests and Provisions (Repeat from 2018) CONDITION: The Authority failed to employ an effective methodology to determine and document the reasonableness of rents charged by owners to Housing Choice Voucher participants in accordance with its written Administrative Plan and HUD regulations. CRITERIA: PHAs are required to determine whether rents charged by owners to Housing Choice Voucher program participants are reasonable, with respect to comparable unassisted units; prior to entering into HAP contracts; when there is a 5 percent or more decrease in the FMR within 60 days of the HAP contract anniversary; and prior to approving any subsequent rent increases in accordance with 24 CFR 982.507. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: During audit fieldwork, 40 HAP contract files from a statistically valid sample were examined for compliance with rent reasonableness determination criteria. Of the 40 files examined, 36 files did not contain evidence to support that sufficient steps had been taken to determine that HAP contract rents paid to owners were reasonable. EFFECT: Failure to determine rent reasonableness provides no assurance that HUD funds are being used efficiently as it may lead to the approval of rents that are too high. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the Housing Choice Voucher program and provide additional training to staff on determining rent reasonableness in accordance with CRHA?s Administrative Plan and HUD regulations.

Finding No. 2019-001 CFDA No. 14.871 Special Tests and Provisions {Repeat from 2018) The Authority concurs that there were deficiencies in the rent reasonableness process. Due to turnover in executive and management staff this issue wasn?t properly addressed. The PHA did not complete and verify all rent reasonableness studies and comparisons were completed for all units in the voucher portfolio. The PHA will continue to address this issue through the recertification and initial certification process and correct any prior deficiencies on a going forward basis. Planned Implementation Date of Corrective Action Plan: December 31, 2019 Person Responsible for Corrective Action Plan: Charlotte Green, Director of Housing (434) 326-4672.

2018-001

Finding No. 2019-002 CFDA No. 14.871 Eligibility CONDITION: The Authority failed to complete annual recertifications in accordance with its Administrative Plan and HUD regulations. CRITERIA: PHAs are required to reexamine family income and composition at least once every 12 months and calculate tenant rents and housing assistance payments in accordance with 24 CFR 982.516. QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: During audit fieldwork, 40 HAP contract files from a statistically valid sample were examined for compliance with annual tenant recertification requirements. Of the 40 files examined, 3 files contained inaccurate calculations of tenant rents and housing assistance payments reported on HUD Form-50058. One file did not contain documentation to support that an annual recertification had been completed including HUD Form 50058. EFFECT: Failure to accurately calculate tenant rent and housing assistance payments as required could lead to inappropriate tenant rent and housing assistance payment charges. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the Housing Choice Voucher program to ensure that annual recertifications include accurate calculations of tenant rent and housing assistance payments reported on HUD Form-50058.

Finding No. 2019-002 CFDA No. 14.871 Eligibility The Authority concurs that there were deficiencies in the HCVP voucher annual recertification process. Due to turnover in executive and management staff this issue wasn?t properly addressed. Annual recertifications and calculation of rent for all units in the voucher portfolio were not completed in a timely fashion or accurately. The PHA will continue to address this issue through the recertification and initial certification process and correct any prior deficiencies on a going forward basis. Planned Implementation Date of Correction Action Plan: December 31, 2019 Person Responsible for Corrective Action Plan: Charlotte Green, Director of Housing (434) 326-4672.

Finding No. 2019-003 CFDA No. 14.871 Special Tests and Provisions CONDITION: The Authority failed to document annual Housing Quality Standards (HQS) inspections in accordance with its Administrative Plan and HUD regulations. CRITERIA: PHAs are required to inspect units leased to Housing Choice Voucher program participants at least annually and prepare unit inspection reports in accordance with 21 CFR 982.158(d). QUESTIONED COSTS: The amount of questioned costs could not be determined. CONTEXT: During audit fieldwork, 40 HAP contract files from a statistically valid sample were examined for compliance with annual HQS inspection requirements. Of the 40 files examined, 27 files did not contain current annual inspection reports. EFFECT: The Authority is not in compliance with federal regulations regarding HQS inspections and documentation. This could result in unallowable HAP payments to owners of units that do not meet required Housing Quality Standards. CAUSE: The overall cause was a lack of management oversight and quality control over this program. RECOMMENDATION: The Authority should implement greater oversight over the Housing Choice Voucher program to ensure that annual inspections are completed and documented at least annually as required.

Finding No. 2019-003 CFDA No. 14.871 Special Tests and Provisions The Authority concurs that there were deficiencies in the HCVP voucher annual Housing Quality Standards (HQS) inspection process. Due to turnover in executive and management staff this issue wasn?t properly completed or reviewed during the fiscal year. All HQS inspections for all units in the voucher portfolio were not completed in a timely fashion. The PHA will continue to address this issue through the next fiscal year and do quality control reviews of prior inspections to insure all have been completed for fiscal year 2020. Planned Implementation Date of Correction Action Plan: December 31, 2019 Person Responsible for Corrective Action Plan: Charlotte Green, Director of Housing (434) 326-4672.

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