COLUMBIA HOUSING AUTHORITY

Finding No. 2024-006; Eligibility and Special Tests and Provisions - Material Weakness Name of Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster (Section 8 Housing Choice Vouchers Program; Emergency Housing Vouchers Program; and Mainstream Vouchers Program) Assistance Listing Numbers: 14.871; 14.879 Federal Award Identification Number and Year: SC002 2024 Criteria In accordance with Uniform Guidance, internal controls are required to be in place to ensure compliance with federal requirements and to maintain complete and accurate participant files as noted in 24 CFR 5.233, 982.158(d) and 982.404. Condition and Context Our testing of 40 participant files noted the following:  No electronic income verification (EIV) was done within the required time period for 1 of 40 participant selections.  No abatement of housing assistance payments of failed unit inspections after 30 day maintenance windows was completed for 1 of 25 participant selections. Cause Tenant lease files are required to be maintained, and tenant eligibility determined in accordance with Uniform Guidance. Effect or Potential Effect The Housing Authority of The City of Columbia is not in compliance with federal requirements regarding Eligibility and Special Tests and Provisions. Questioned Costs Unknown Identification as a Repeat Finding This finding is not a repeat finding. Recommendation The Housing Authority of The City of Columbia should maintain complete and accurate participant files to ensure compliance with federal program requirements. Views of Responsible Officials(s) and Planned Corrective Actions The Housing Authority of The City of Columbia will improve internal controls to maintain complete and accurate participant files to ensure compliance with federal requirements.

Finding No. 2024-007; Activities Allowed or Unallowed - Material Weakness Name of Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster (Section 8 Housing Choice Vouchers Program; Emergency Housing Vouchers Program; and Mainstream Vouchers Program) Assistance Listing Number: 14.871; 14.879 Federal Award Identification Number and Year: SC002 2024 Condition and Context Testing of interfund receivable balances owed to the Housing Choice Voucher Program (HCVP) and the Emergency Housing Vouchers Program (EHV) from other programs indicated unallowable uses of grant funds as noted in 24 CFR 982.151 and 982.152. Criteria Public Housing Authorities may use HCVP, EHV and Mainstream Voucher funds only for housing assistance payments to participating owners, and for associated administrative fees. Cause During the year ended June 30, 2024, HCV and EHV funds were advanced to other programs resulting in HCVP and EHV funds being used to cover costs for other federal programs and nonfederal programs. Effect or Potential Effect During the year ended June 30, 2024, the Authority used $168,899 of EHV funds and $403,752 of HCVP funds to make advances for $130,842 to the Mainstream Program, and $441,809 to cover costs of other programs in violation of HCVP and EHV program requirements. Questioned Costs $441,809 Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that the Authority reconcile and settle interfund balances on a timely basis. In addition, we recommend the Authority establish controls over HCVP and EHV grant revenue to ensure funding does not become intermingled with other programs and the outstanding advances are returned to the HCVP and EHV programs. Views of Responsible Officials(s) and Planned Corrective Actions The Authority concurs with the finding and agrees with the recommendation. The Authority has begun the process of reconciling interfund balances to ensure balances are settled on a timely basis and funds are not intermingled with other federal programs.

2021-001 - Participant Files Section 8 Housing Choice Vouchers Program - ALN No. 14.871 Mainstream Vouchers - ALN No. 14.879 Material Weakness in Internal Control; Material Noncompliance Eligibility, Reporting, Special Tests and Provisions Criteria: Internal controls are required to be in place to ensure compliance with federal requirements and to maintain complete and accurate participant files. Condition: Our testing of 40 participant files noted the following: No support was able to be provided regarding tenant lease files for 8 of 40 participant selections. No support was able to be provided that the HUD form 50058 was completed to support the cash disbursement for 4 of 40 participants. No support was able to be provided regarding proper utility allowance for 4 of 40 participant files. No support was able to be provided that annual HQS inspections were completed for 27 of 40 participant files. Effect or Potential Effect: The Housing Authority of the City of Columbia is not in compliance with federal requirements regarding Eligibility, Reporting, and Special Tests and Provisions. Cause: The Housing Authority of the City of Columbia was in the process of transitioning to digital records and was unable to locate copies of hard copy documents in storage that had not been digitized. Recommendation: The Housing Authority of the City of Columbia should maintain complete and accurate participant files to ensure compliance with federal requirements.

2021-002 - Participant Files Public and Indian Housing - ALN No. 14.850 Material Weakness in Internal Control; Material Noncompliance Eligibility, Special Tests and Provisions Criteria: Internal controls are required to be in place to ensure compliance with federal requirements and to maintain complete and accurate participant files. Condition: Our testing of 40 participant files noted the following: No support was able to be provided that the HUD form 50058 was completed for 7 of 40 participants. No support was able to be provided that proper EIV income verification was completed for 4 of 40 participant files. No support was able to be provided that HUD form 9886 was completed for 7 of 40 participant files. No support was able to be provided that move-in inspections were completed for 6 of 40 participant files. No support was able to be provided that a lead-based paint warning statement was completed for 6 of 40 participant files. No support was able to be provided that approval for tenant screening was completed for 40 of 40 participant files. Effect or Potential Effect: The Housing Authority of the City of Columbia is not in compliance with federal requirements regarding Eligibility, Reporting, and Special Tests and Provisions. Cause: The Housing Authority of the City of Columbia was in the process of transitioning to digital records and was unable to locate copies of hard copy documents in storage that had not been digitized. Recommendation: The Housing Authority of the City of Columbia should maintain complete and accurate participant files to ensure compliance with federal requirements.

2021-003 - Declarations of Trust Public and Indian Housing - ALN No. 14.850 Material Weakness in Internal Control; Material Noncompliance Special Tests and Provisions Criteria: Internal controls are required to be in place to ensure compliance with federal requirements and to record and maintain current Declarations of Trust (DOT). Condition: No support was able to be provided to support that a current DOT is recorded against 36 public housing projects. Effect or Potential Effect: The Housing Authority of the City of Columbia is not in compliance with federal requirements regarding Special Tests and Provisions. Cause: The Housing Authority of the City of Columbia had a change in management in the previous year and was unable to locate copies of the documents. Recommendation: The Housing Authority of the City of Columbia should locate or obtain replacement copies of all DOT to ensure compliance with federal requirements.

2020-001 - Participant Files Section 8 Housing Choice Vouchers Program - CFDA No. 14.871 Mainstream Vouchers - CFDA No. 14.879 Material Weakness in Internal Control; Material Noncompliance Eligibility, Reporting, Special Tests and Provisions Criteria: Internal controls are required to be in place to ensure compliance with federal requirements and to maintain complete and accurate participant files. Condition: Our testing of 40 participant files noted the following: ? No support was able to be provided regarding proper utility allowance for 9 of 40 participant files. ? No support was able to be provided that proper EIV income verification was completed for 3 of 40 participant files. ? No support was able to be provided that annual HQS inspections were completed for 18 of 40 participant files. Effect or Potential Effect: The Housing Authority of the City of Columbia is not in compliance with federal requirements regarding Eligibility, Reporting, and Special Tests and Provisions. Cause: The Housing Authority of the City of Columbia was in the process of transitioning to digital records and was unable to locate copies of hard copy documents in storage that had not been digitized. Recommendation: The Housing Authority of the City of Columbia should maintain complete and accurate participant files to ensure compliance with federal requirements.

2019-001 Eligibility ? Tenant Files Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: Out of a total tenant population of approximately 3,400 vouchers, 25 files were selected for testing. Exceptions were noted as follows: ? 2 tenant filest had no support for the tenant?s annual or interim re-certifications for the 2019 fiscal year. As a result, tenant?s income, assets, deductions, expenses and allowances were not verified and the EIV report was not obtained. As such, HAP payments may be incorrect and the Form 50058 may not be reporting correct data. In addition, tenant?s eligibility in the Section 8 program could not be determined. ? 1 tenant file was missing a tenant application ? 1 tenant file did not have an established HAP contract between the Authority and the landlord. ? 1 tenant file where the HAP contract was not signed or dated by the landlord. ? 1 tenant file that did not have an established lease agreement between the tenant and the landlord. ? 1 tenant file was missing a signed lead paint form. ? 1 tenant file where the social security number was reported incorrectly on the Form 50058. ? 1 tenant file where the HAP rent should have been reported on the 50058 form for $564 instead of $476. The HAP rent of $476 (as reported on the 50058 form) was miscalculated due to an incorrect utility allowance amount used and due to child care income not being verified in the current year annual recertification. In addition, we also noted as part of new admissions testing (25 files tested out of approximately 425 new admissions) the following: ? 9 tenant files where the tenants signed the 214 Affidavit forms 6-8 months after the tenants move-in date. ? 1 tenant file where the 214 form was never signed by the tenant. ? 4 tenant files where the criminal backgrounds were performed on VASH applicants. ? 1 tenant file where the Request for Tenancy Addendum was not executed within the voucher period. ? 1 tenant file where a voucher was issued for the incorrect bedroom size based on the family size. However, the 50058 form shows that the authority is using the correct voucher size (payment standard) for the family. ? 2 tenant files where the rent reasonableness procedures were never performed or the forms are missing from the tenant files. ? 3 tenant files where the HAP contract was signed 4-6 months after the tenant?s move-in date. ? 2 tenant files where the HAP contract was not signed or dated by the landlord. ? 1 tenant file where the signature page of the HAP contract is missing from the tenant file. ? 1 tenant file where the passed inspection form is missing from the tenant file. 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: During the last 6 months of the fiscal year, Section 8 personnel appeared to be overtasked by maintaining the Section 8 program while simultaneously issuing tenant protection vouchers for Public Housing tenants impacted by the condemnation of the Allen Benedict Court property. As such, procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Auditor?s 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 are aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: New leadership at the Authority recognized the deficiencies in the tenant files and limited staff knowledge and skills. The Director of the Housing Choice Voucher program has been replaced with an extremely qualified Leader for the department. Nan McKay and Associates conducted a skill assessment of all staff and an agency wide reorganization is underway. A Comprehensive Training Plan and Quality Control Program will also be implemented in 2020. Corrections required in the identified files will be completed by March 31, 2020.

2019-002 Special Tests and Provisions - Housing Quality Standard (HQS) Failed Inspections Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: Out of a population of approximately 590 failed inspections, 25 inspections were selected for testing, but stopped testing after 19 files after it was determined this would be a finding. Exceptions were noted as follows: ? 1 file where an abatement never occurred for the months of November and December 2018. ? 1 file where an abatement never occurred for the month of July 2019. ? 1 file where there was no documentation showing that the unit passed inspection and an abatement never occurred 30 days after the initial failed inspection. ? 1 file where an abatement never occurred for the months of February to April 2019. ? 1 file where the re-inspection did not occur until two and a half months after the initial failed inspection. In addition, an abatement never occurred for the months of August and September 2019. ? 1 file where the re-inspection did not occur until 40 days after the initial failed inspection. ? 1 file where the re-inspection did not occur until 6 months after the initial failed inspection. In addition, an abatement never occurred for the months of October 2018 to February 2019. ? 1 file where the re-inspection never occurred and an abatement of the HAP rent never occurred. Criteria: HUD regulations require that units leased to a family are inspected at least annually to determine if the unit meets Housing Quality Standards (HQS). In addition, inspections must be documented on a unit inspection report. For units that fail inspections, any life threatening deficiencies must be corrected within 24 hours and all other deficiencies must be corrected within 30 calendar days or within a specified PHA-approved extension. If the deficiency is not corrected, the HAP payment must be abated no later than the first of the following month. Questioned Costs: None. Effect: The Authority is not in compliance with applicable HUD regulations. Cause: During the last 6 months of the fiscal year, Section 8 personnel appeared to be overtasked by maintaining the Section 8 program while simultaneously issuing tenant protection vouchers for Public Housing tenants impacted by the condemnation of the Allen Benedict Court property. As such, procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Auditor?s Recommendation: The Authority should make sure that failed HQS inspections are properly documented on the inspection report and done within the required time frame or are properly abated. If the Authority doesn?t do the inspection within the required time frame and doesn?t abate the HAP payment, the Authority should document the reason in order to determine if it was reasonable. Also, the Authority should assure that all critical repairs for life threatening deficiencies are completed within 24 hours. Views of Responsible Officials of the Auditee: New leadership at the Authority recognized the deficiencies in the HQS inspections process and limited staff knowledge and skills. HQS inspections will be out-sourced to a Professional Inspections firm in 2020. The independent vendor will also be required to provide a Quality Control Program to include reinspection of a minimum of 5% of all inspections with monthly reports of all results to the Authority. The Authority will also randomly select a sample of the QC inspections and conduct monitoring inspections for an additional layer of QC. Corrections required in the identified files will be completed by March 31, 2020.

2019-003 Special Tests and Provisions: Quality Control Inspections Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: The Authority was required to perform 38 quality control inspections and conducted the required amount. However, 9 quality control inspections were performed outside the required 90-day time frame. In addition, all of the quality control inspections were selected from initial inspections occurring in the months of March through June 2019. No quality control inspections occurred for the months of July 2018 through February 2019. Criteria: 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)). The re-inspection must occur within 90 days of the original inspection. Questioned Costs: None. Effect: The Authority is not in compliance with Housing Quality Standards (HQS) which may result in unit HQS deficiencies and unsafe living accommodations. Cause: The Authority did not have adequate internal controls in place over Housing Quality Standards (HQS) and did not perform the re-inspection timely. Auditor?s Recommendation: The Authority should increase training to employees to insure that the Authority is in compliance with HUD rules for quality control re-inspections. In addition, the Authority should assure that proper records are maintained for inspections and quality control re-inspections. Views of Responsible Officials of the Auditee: New leadership at the Authority recognized the deficiencies in the HQS inspections process and limited staff knowledge and skills. HQS inspections will be out-sourced to a Professional Inspections firm in 2020. The independent vendor will also be required to provide a Quality Control Program to include reinspection of a minimum of 5% of all inspections with monthly reports of all results to the Authority. The Authority will also randomly select a sample of the QC inspections and conduct monitoring inspections for an additional layer of QC. Corrections required in the identified files will be completed by March 31, 2020.

2019-004 Special Tests and Provisions: Utility Allowance Study Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: A utility allowance study was not conducted for the 2019 fiscal year and the utility allowance rates used were based on a study conducted in 2017. Criteria: 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. Questioned Costs: None. Effect: The Authority is not in compliance with HUD regulations regarding utility allowances and, as such, the tenant rents calculated may not be accurate. Cause: The Authority did not have adequate internal controls in place over the determination of utility allowance schedule amounts and a recent study of the utility rates was not performed. Auditor?s Recommendation: The Authority should increase training to employees to insure that the Authority is in compliance with HUD rules for utility allowance determination. In addition, the Authority should assure that the utility allowance schedule is modified if a rate change of 10% or more for utilities occurred by performing a study and documenting the results of the study. Views of Responsible Officials of the Auditee: New leadership at the Authority recognized the deficiencies in establishing and updating utility allowance studies and schedules. Action was taken to contract with the Nelrod Company, a national company with expertise in conducting the required HUD utility allowance studies. As of the date of this response, the study has been completed and appropriate utility allowances have been implemented. Corrections required in the identified files will be completed by March 31, 2020.

2019-005 Reporting: HCV SEMAP Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Material Weakness in Internal Control, Material Noncompliance Condition: The Authority did not have adequate controls over the Section 8 Management Assessment Program (SEMAP) reporting to assure that the Authority is in compliance with this requirement. The self assessement did not include sufficient amounts for testing and the documentation provided for the SEMAP reporting did not appear to substantiate some of the SEMAP results. For 3 indicators, the Authority did not select sufficient amounts to test and/or the Authority?s results did not agree with the self assessment score as follows: ? Indicator 2 ? Rent Reasonableness: The Authority was required to select a sample size of 38 tenant files to determine whether or not rent reasonableness procedures are being followed. The PHA only selected 35 tenant files for testing. o From the tenant files selected by the Authority, there was 1 file where the tenant?s unit was not comparable to the other comparable units. o From the tenant files selected by the Authority, there were 3 files where there was no support of the rent comparable form. Based on the above, the Authority should have reported a total of 15 points and not 20 points on the SEMAP for this indicator. ? Indicator 5 ? HQS Quality Control: The Authority selected a sample size of 38 tenant files for their quality control inspections. However, the sample only included inspections from March 2019 ? June 2019. The PHA should select inspections throughout the year for testing. In addition, there were 9 quality control inspections that occurred after the 90 day time frame. Based on the above, the Authority should have reported 0 points and not 5 points on the SEMAP. ? Indicator 6 ? HQS Enforcements: The Authority was required to select a sample size of 38 tenant files to determine whether or not HQS enforcement procedures are being performed. The PHA only selected 5 inspections for testing. Based on the finding above, the Authority should have reported 0 points and not 10 points. Criteria: The Section 8 Management Assessment Program (SEMAP) is a self-assessment tool that measures the performance of public housing agencies (PHAs) that administer the housing choice voucher program in 14 key areas. SEMAP helps HUD target monitoring and assistance to PHA programs that need the most improvement. The 14 indicators of performance show whether PHAs help eligible families to afford decent rental units at a reasonable subsidy cost as intended by Federal housing legislation. HUD annually assigns each PHA a rating on each of the 14 indicators and an overall performance rating of high, standard, or troubled. Questioned Costs: None. Effect: The Authority does not appear to be in compliance with HCV SEMAP reporting requirements and as such is not reporting accurate information to HUD which could change the performance rating. Cause: The Authority did not have sufficient internal controls to assure accurate SEMAP reporting. Auditor?s Recommendation: We recommend that the Authority design and implement internal controls over SEMAP to assure the Authority is in compliance with HUD requirements. Views of Responsible Officials of the Auditee: New leadership at the Authority recognized the deficiencies in tracking and monitoring the SEMAP performance indicators. The Director of the Housing Choice Voucher program has been replaced with an extremely qualified Leader for the department. An internal confirmatory review will be conducted by Management prior to submission of the annual SEMAP certification. The random sample for the applicable indicators will be selected by Executive Management outside the HCV Department and the corresponding SEMAP PIC reports will be monitored on a quarterly basis to address any outstanding issues prior to year end.

2019-006 Special Tests and Provisions: Tenant File Testing and Reasonable Rental Rates Continuum of Care Program ? CFDA Number 14.267 Material Weakness in Internal Control, Material Noncompliance Condition: In our review of 6 Continuum of Care tenant files (out of population of 60 tenants), we noted the following: ? 6 files reviewed where there was no evidence of rent reasonableness being performed on the units. ? 6 files where no evidence of HQS inspections being performed during the fiscal year. ? 3 files where there was no documentation of the initial unit inspection at move-in being performed. ? 5 files where the tenant sublease agreement was not in the file. ? 3 files where the tenant rental income calculation was not in the file and we were not able to verify the tenant rent. ? 1 file where there was an error in the tenant rent calculation which resulted in the tenant paying $301 per month (instead of the correct tenant rent amount of $366). ? 1 file where there was no documentation in the file of case management services being provided. Criteria: The Continuum of Care (CoC) Program is designed to (1) promote community-wide commitment to the goal of ending homelessness; (2) provide funding for efforts by non-profit providers, States, and local governments to quickly re-house homeless individuals and families while minimizing the trauma and dislocation caused to homeless individuals, families, and communities by homelessness; (3) promote access to and effective utilization of mainstream programs by homeless individuals and families; and (4) optimize self-sufficiency among individuals and families experiencing homelessness. Internal controls should be in place to ensure compliance with HUD requirements, as well as complete and accurate tenant files. Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units, and the portion of rents paid with grant funds may not exceed HUD-determined fair market rents. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding rent reasonableness, HQS standards and tenant certification and recertification, which could result in incorrect total tenant payments for rent and payments to landlords. Cause: Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Auditor?s 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 certification and recertification, rent reasonableness and HQS inspections. 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: Procedures described above will also be implemented for the COC Programs to assure compliance with all program regulatory requirements. Corrections required in the identified files will be completed by March 31, 2020.

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