Housing Authority of the CIty of Greenville

2024-001 – Eligibility – Moving to Work Demonstration Program - 14.881 Significant Deficiency Statement of Condition and Criteria The audit noted instances of late annual recertifications and insufficient income documentation. PHA’s are required to determine income eligibility, calculate participant rent and housing assistance payments on an annual basis using verified participant income documentation. Cause Significant staff turnover in the prior year as well as ongoing corrections to prior compliance issues. Effect or Potential Effect Potential overpayment of Housing Assistance Payments Context A sample of 40 files were selected to audit program eligibility from a population of 3,089. The test found 3 files noted late annual recertifications and 3 files with old or incorrect income documentation. Recommendation We recommend the Authority continue its work in addressing staff workload and review document workflow to ensure tasks are carried out through completion. Management’s Response Management agrees with the finding and corrective action is in progress as detailed in the Corrective Action Plan.

The initial eligibility determinations are currently handled by the HCV department and are centralized. It has been determined that considerable investment in staff training has been made during the past twelve months. As a result, there has been staff turnover, some at the decision of TGHA, and some at the decision of staff. Initial eligibility is currently being restructured with an emphasis on new admissions. All procedures and processes are being evaluated for accuracy, with emphasis on the noted area of noncompliance and includes a complete review and update to the Administrative Plan. There will be increased staff training and file review. In July 2024, TGHA transitioned project-based files from a property management team to the Housing Choice Voucher Department. The files had not been electronically stored. Evidence pointed to deficiencies in file maintenance. TGHA has hired temporary staff for an extended period to focus on file organization and to correct documentation deficiencies. All HCV staff have completed Rent Calculation courses provided by NAHRO or Nan McKay during the fiscal year. There have been two managers hired for the department, one exclusively for project-based vouchers. Both attended NAHRO supervisory training in September. There will be an intensive focus on program integrity throughout the programs, including staff capability, training and monitoring. TGHA has contracted with a professional recruiter to assist in hiring a Director of the HCV and MTW programs. Recertification transactions will be monitored on a monthly basis. This will include validation of calculations and verification of correct documentation. TGHA files were fully in order by July 2025.

2023-002

2023-001 – Eligibility - Moving to Work Demonstration Program - 14.881 Material Weakness and Material Noncompliance Statement of Condition and Criteria Participant files were missing, incomplete or insufficient to substantiate eligibility determinations. PHA’s are required to maintain and retain documentation in accordance with federal document retention policies to substantiate the ongoing eligibility of participants. Cause Lack of effective oversight of certification procedures conducted at site offices, including outside contracted management agencies. In addition, conversion to electronic workpaper retention, as well as system conversions resulting in loss of data. Effect or Potential Effect Potential overpayment of housing assistance. Question Costs Not determined. Context A sample of 45 files were selected to audit program eligibility from a population of 2,766. The test found 16 files did not pass audit inspection due to missing significant supporting documentation to support the calculation of housing assistance. Our sample was not a statistically valid sample. Recommendation We recommend the Authority centralize eligibility determinations to assist with enforcement and quality control review of program procedures. This would include removing responsibilities from both external and internally managed sites to better align staff and program responsibilities. Management’s Response Management agrees with the finding and corrective action is in progress as detailed in the Corrective Action Plan.

Corrective Action The initial eligibility determinations are currently handled by the HCV department and are centralized. It has been determined that considerable investment in staff training has been made during the past twelve months. As a result, there has been staff turnover, some at the decision of TGHA, and some at the decision of staff. Initial eligibility is currently being restructured with an emphasis on new admissions. All procedures and processes are being evaluated for accuracy, with emphasis on the noted area of noncompliance and includes a complete review and update to the Administrative Plan. There will be increased staff training and file review. In July 2024, TGHA transitioned project-based files from a property management team to the Housing Choice Voucher Department. The files had not been electronically stored. Evidence pointed to deficiencies in file maintenance. TGHA has hired temporary staff for an extended period to focus on file organization and to correct documentation deficiencies. All HCV staff have completed Rent Calculation courses provided by NAHRO or Nan McKay during the fiscal year. There have been two managers hired for the department, one exclusively for project-based vouchers. Both attended NAHRO supervisory training in September. There will be an intensive focus on program integrity throughout the programs, including staff capability, training and monitoring. TGHA has contracted with a professional recruiter to assist in hiring a Director of the HCV and MTW programs. Recertification transactions will be monitored on a monthly basis. This will include validation of calculations and verification of correct documentation. It is anticipated that TGHA files will be fully in order by July 2025.

2023-002 – Eligibility – Moving to Work Demonstration Program - 14.881 Significant Deficiency and Reportable Noncompliance Statement of Condition and Criteria Annual recertifications were not completed in a timely manner. PHA’s are required to determine income eligibility, calculate participant rent and housing assistance payments on an annual basis. Cause Staff turnover along with ineffective tracking and finalization of eligibility determinations. Effect or Potential Effect Overpayment of Housing Assistance Payments due to late processing of annual recertifications. Question Costs Known questioned costs totaled $2,390. Context A sample of 45 files were selected to audit program eligibility from a population of 2,796. The test found 26 files noted late annual recertifications. Of which, seven files required additional housing assistance to be disbursed due to sufficient participant notice requirements. Our sample was not a statistically valid sample. Recommendation We recommend the Authority reassess staff workload and review document workflow to ensure tasks are carried out through completion. Management’s Response Management agrees with the finding and corrective action is in progress as detailed in the Corrective Action Plan.

Corrective Action The program issues are systemic; therefore the corrective actions are identical. The MTW flexibility permits tri-annual recertification. The agency has been conducting tri-annual recertification for elderly and disabled households. Effective with February 2025 recerts, now in process, tri-annuals will be applied to all households. This significantly reduces the number of recertifications performed by each staff and permits significantly more attention to monitoring, oversight, training and correction. TGHA has hired temporary staff for an extended period to focus on file organization and to correct documentation deficiencies. All HCV staff have completed Rent Calculation courses provided by NAHRO or Nan McKay during the fiscal year. There have been two managers hired for the department, one exclusively for project-based vouchers. Both attended NAHRO supervisory training in September. There will be an intensive focus on program integrity throughout the year. TGHA has contracted with a professional recruiter to assist in hiring a Director of the HCV and MTW programs. Recertification transactions will be monitored on a monthly basis. This will include validation of calculations and verification of correct documentation. It is anticipated that TGHA files will be fully in order by July 2025.

2022-001 ? Eligibility - Housing Choice Voucher - 14.871 Significant Deficiency and Material Noncompliance Statement of Condition and Criteria Participant file documentation was incomplete or insufficient to substantiate annual eligibility determinations. Numerous immaterial errors occurred during the annualization of participant income using documentation obtained. PHA?s are required to determine income eligibility, calculate participant rent and housing assistance payment using sufficient, appropriate documentation in accordance with HUD regulations. Cause Lack of staff adherence to administrative policies related to annualizing income and ineffective training procedures. Effect or Potential Effect Overpayment of Housing Assistance Payments due to income calculation errors. Question Costs Known questioned costs totaled $10,903. Context A sample of 40 files were selected to audit program eligibility from a population of 3,166. The test found 11 files with some form of income calculation deficiency, 6 of which contributed to the known question cost. In addition, one file did not contain sufficient documentation to test the recertification process. Our sample was not a statistically valid sample. Recommendation We recommend the Authority increase training and cross-training to better prepare staff to adjust to periods of high turnover and increased supervisory and quality control reviews, to ensure compliance with HUD regulations. Management?s Response Management agrees with the finding and corrective action is in progress as detailed in the Corrective Action Plan.

The findings from the Summary of Auditor's Results: Section Ill - Federal Award Findings 2022-001 - Eligibility - Housing Choice Voucher - 14.871 Significant Deficiency and Material Noncompliance Summary of Condition and Criteria Incomplete documentation and income calculation errors. Recommendation We recommend the Authority increase training and cross-training to better prepare staff to adjust to periods of high turnover and increased supervisory and quality control reviews, to ensure compliance with HUD regulations. Corrective Action The HCV department is recently under new management; all procedures are being evaluate for accuracy, with emphasis on the noted area of noncompliance. There will be increased staff training and file review.

2020-001 ? Eligibility ? Housing Choice Voucher ? CFDA# 14.871 Significant Deficiency and Material Noncompliance Statement of Condition and Criteria Income calculations performed during annual re-examinations contained errors. Errors primarily relate to the annualization of participant income using documentation obtained. PHA?s are required to determine income eligibility, calculate participant rent and housing assistance payment using sufficient, appropriate documentation in accordance with HUD regulations. Cause Lack of staff adherence to administrative policies related to annualizing income and ineffective quality control procedures. Effect or Potential Effect Overpayment of Housing Assistance Payments due to income calculation errors. Question Costs Known questioned costs totaled $4,958. Context A sample of 40 files were selected to audit program eligibility from a population of 2,926. The test found 8 files with some form of income calculation deficiency, 3 of which contributed to the known question cost. Our sample was a statistically valid sample. Recommendation We recommend the Authority continue its corrective action regarding updating income calculation policies used to annualize income and monitor staff performance, including increased quality control reviews, to ensure compliance with HUD regulations. Management?s Response Management agrees with the finding and corrective action is in progress as detailed in the Corrective Action Plan.

U.S. Department of Housing and Urban Development Finding 2020-001- Eligibility - Housing Choice Voucher - CFDA 14.871 Recommendation: It was recommended the Authority continue its efforts of enhancing its corrective action plan regarding updating income calculation policies used to annualize income and monitor staff performance, including increased quality control reviews, to ensure compliance with HUD regulations. Action Taken: Since late 2020, new management has implemented new policies and procedures to reduce errors with income calculations. These polices and procedures include a new comprehensive Administrative Plan, Third-Party Rent Calculations training and testing, along with an increase in the quantity of files to be reviewed.

2020-002 ? Eligibility ? Low Rent Public Housing ? CFDA# 14.850 Significant Deficiency Statement of Condition and Criteria Tenant files were incomplete and did not contain all documentation used to complete annual and initial tenant recertifications. PHA?s are required to determine income eligibility and calculate the tenant?s rent payment using sufficient, appropriate documentation in accordance with HUD regulations. Cause Insufficient oversight of third-party property management agents. Effect or Potential Effect Inability to substantiate rents charged to residents or otherwise effectively monitor program compliance. Recommendation We recommend the Authority increase quality control review of third-party management companies to ensure file compliance with program requirements. Management?s Response Management agrees with the finding and corrective action is in progress as detailed in the Corrective Action Plan.

Finding 2020-002 - Eligibility- Low Rent Public Housing - CFDA 14.850 Recommendation: It was recommended that the Authority increase quality control review of third-party management companies to ensure compliance with program requirements. Action Taken: The Authority has implemented a quality control review program over it's thirdparty management agents to ensure compliance with HUD Program requirements.