Housing Authority of the City of YorkLocal Government

2023-001 Eligibility – Tenant Files Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-001 from June 30, 2022 (initially reported June 30, 2021) Statement of Condition Out of a total tenant population of approximately 194 vouchers, 20 files were selected for testing. Exceptions were noted as follows: • 1 file where a math error on zero-income calculation resulted in an increase in HAP rent from $709 to $712. • 1 file where a math error on zero-income calculation resulted in a decrease in HAP rent from $961 to $912. • 1 file where social security income was calculated using 2022 amounts despite move-in date in February 2023. As a result, HAP rent decreased from $561 to $546. • 1 file where social security income was calculated using 2022 amounts despite annual re-exam in February 2023. As a result, HAP rent decreased from $709 to $687. In addition to the above, during our new admissions testing (5 tested out of 44 new admissions) we noted the following: • 1 file that did not contain a signed lease agreement. Criteria 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertification, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Recommendation The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee We concur with the recommendation and have implemented various controls. A tenant file and unit quality control procedure has been developed and implemented. See corrective action plan.

2023-002 Special Tests and Provisions – Income Targeting Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-002 from June 30, 2022 (initially reported June 30, 2021) Statement of Condition The Authority did not have adequate controls over income targeting to assure that the Authority is in compliance with this requirement. During our testing, we noted that tenants with incomes that were extremely low accounted for approximately 70% of new admissions during the fiscal year, which is below the minimum required percentage of 75%. Criteria During each fiscal year, at least 75% of the Authority’s new admissions in the Housing Choice Voucher Program must have incomes that do not exceed 30% of the area median income (“extremely low”) as published by HUD. Questioned Costs None. Effect The Authority does not appear to be in compliance with Section 8 income targeting requirements. Cause The Authority did not have sufficient internal controls in place to track income targeting. Recommendation We recommend the Authority assure that at least 75% of new admissions be in the extremely low-income bracket. This should be monitored throughout the year. The Authority can also select applicants on the waiting list who are extremely low income by bypassing others on the list that don’t meet the requirement and documenting that the person was selected ahead of others to be able to meet the requirement. Views of Responsible Officials of the Auditee: We concur with the recommendation. We will closely monitor new admissions and focus on applicants on the waiting list who meet the criteria as extremely low income so that the 75% requirement is met.

2022-001 Eligibility ? Tenant Files Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-001 from June 30, 2021 Statement of Condition Out of a total tenant population of approximately 200 vouchers, 20 files were selected for testing. Exceptions were noted as follows: ? 1 error where the utility allowance was calculated incorrectly and reported incorrectly on the 50058 form. The HAP rent amount did not change. ? 1 file where the tenant?s wage income was calculated using only one paystub even though the tenant provided two. This changes the tenant?s HAP rent from $592 to $579. ? 1 file where the $360 for food stamps was included in the tenant?s income and should have been excluded. This changes the HAP rent from $466 to $475. ? 1 file where there was no support for a full-time student deduction for one member of the household. The HAP rent amount did not change. ? 1 file that did not contain a signed lease agreement and HAP contract for the current landlord and unit address. In addition to the above, during our new admissions testing (3 tested out of 22 new admissions) we noted the following: ? 1 error where the request for tenancy form was signed three days after voucher expiration with no proof of extension in the file. ? 1 error where the HAP contract was signed by the owner more than 11 months after the move-in date. Criteria 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as complete and accurate tenant files. In addition, the Authority?s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertification, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Recommendation The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee We concur with the recommendation and have implemented various controls. A tenant file and unit quality control procedure has been developed and implemented. See corrective action plan.

2022-002 Special Tests and Provisions ? Income Targeting Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from June 30, 2021 Statement of Condition The Authority did not have adequate controls over income targeting to assure that the Authority is in compliance with this requirement. During our testing, we noted that tenants with incomes that were extremely low accounted for approximately 59% of new admissions during the fiscal year, which is below the minimum required percentage of 75%. Criteria During each fiscal year, at least 75% of the Authority?s new admissions in the Housing Choice Voucher Program must have incomes that do no exceed 30% of the area median income (?extremely low?) as published by HUD. Questioned Costs None. Effect The Authority does not appear to be in compliance with Section 8 income targeting requirements. Cause The Authority did not have sufficient internal controls in place to track income targeting. Recommendation We recommend the Authority assure that at least 75% of new admissions be in the extremely low-income bracket. This should be monitored throughout the year. The Authority can also select applicants on the waiting list who are extremely low income by bypassing others on the list that don?t meet the requirement and documenting that the person was selected ahead of others to be able to meet the requirement. 2022-002 Special Tests and Provisions ? Income Targeting (Continued) Views of Responsible Officials of the Auditee: We concur with the recommendation. We will closely monitor new admissions and focus on applicants on the waiting list who meet the criteria as extremely low income so that the 75% requirement is met.

2021-001 Eligibility ? Tenant Files Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matters to Reported Under the Uniform Guidance Statement of Condition Out of a total tenant population of approximately 200 vouchers, 20 files were selected for testing. Exceptions were noted as follows: ? 1 error where the Authority incorrectly used 3 bedrooms for calculating the utility allowance and should have used 1 bedroom. The tenant?s HAP amount changed from $297 to $272. ? 1 file where three separate income errors were made ? one of the tenant?s income was incorrectly attributed to another member of the household, one of the tenant?s reported wage income had no support, and another where the Authority used only one out of four provided paystubs to calculate the income for another member, which changed the income from $17,013 to $22,037. The file also contained an error where the Authority took an extra dependency deduction for a member of the household age 21, with no support for being a full-time student. Combined these errors changed the HAP payment from $420 to $534. ? 1 file where the utility allowance was calculated incorrectly and where income attributed to one member of the household was excluded despite no support for being a full-time student. These errors change the HAP amount from $550 to $333. ? 1 file where a tenant was incorrectly given a disability exemption despite the tenant no longer being disabled. This changes the HAP from $421 to $411. Criteria 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as complete and accurate tenant files. In addition, the Authority?s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertification, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Recommendation The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee We concur with the recommendation and have implemented various controls. A tenant file and unit quality control procedure has been developed and implemented. See corrective action plan.

2021-002 Special Tests and Provisions ? Income Targeting Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matters to Reported Under the Uniform Guidance Statement of Condition The Authority did not have adequate controls over income targeting to assure that the Authority is in compliance with this requirement. During our testing, we noted that tenants with incomes that were extremely low accounted for approximately 64% of new admissions during the fiscal year, which is below the minimum required percentage of 75%. Criteria During each fiscal year, at least 75% of the Authority?s new admissions in the Housing Choice Voucher Program must have incomes that do no exceed 30% of the area median income (?extremely low?) as published by HUD. Questioned Costs None. Effect The Authority does not appear to be in compliance with Section 8 income targeting requirements. Cause The Authority did not have sufficient internal controls in place to track income targeting. Recommendation We recommend the Authority assure that at least 75% of new admissions be in the extremely low-income bracket. This should be monitored throughout the year. The Authority can also select applicants on the waiting list who are extremely low income by bypassing others on the list that don?t meet the requirement and documenting that the person was selected ahead of others to be able to meet the requirement Views of Responsible Officials of the Auditee: We concur with the recommendation. We will closely monitor new admissions and focus on applicants on the waiting list who meet the criteria as extremely low income so that the 75% requirement is met.

2020-001 Housing Quality Standards Inspections & HQS Enforcement: Special Tests and Provisions Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Compliance and Material Weakness in Internal Control over Compliance Statement of Condition Housing Quality Standards Inspections: Housing Quality Standards were not performed for the fiscal year. HQS Enforcement: 10 out of a total population of 43 failed inspections were selected for testing. Exceptions were noted as follows. ? 2 errors where there was no documentation indicating that the failed inspection units ever passed inspections. ? 2 errors where the re-inspection did not occur until after 30 days of when the initial inspection was performed. Criteria Housing Quality Standards Inspections: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). HQS Enforcement: For units under HAP contract that fail to meet Housing Quality Standards (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. 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 PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Questioned Costs: None. Effect The Authority is not in compliance with Housing Quality Standards Inspections and HQS Enforcement which may result in HQS deficiencies and unsafe living accommodations. Cause The Authority did not have adequate internal controls in place over Housing Quality Standards Inspections and HQS Enforcement. Recommendation The Authority should increase training to its employees to ensure that the Authority is in compliance with HUD rules and regulations by assuring Housing Quality Standards Inspections and HQS Enforcement are being performed timely and maintaining proper records. Views of Responsible Officials of the Auditee We concur with the recommendation. The Authority is now assuring Housing Quality Standards Inspections and HQS Enforcement are being performed timely and maintaining proper documentation.

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