Housing Authority of the City of Benton

2025-003 Missing Tenant Files Condition: Tenant files are not being properly maintained. During our review of testing related to HCV tenants we noted 8 files which could not be located. Criteria: HUD regulations require tenant files be maintained for at least three years after termination of assistance/tenancy. Context: The Authority had tenant files destroyed and it is believed these missing files were inadvertently destroyed. Effect: Missing tenant files prohibit the auditor from verifying the Authority’s compliance with various HUD regulations. Recommendation: We recommend the Authority develop a policy and tracking methodology for destroying tenant files.

2025-004 Review of Utility Rate Data Condition: The Authority failed to substantiate the rate difference incurred in the current fiscal year. Criteria: Per 24 CFR section 982.517, the Authority 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% or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Context: While reviewing the utility allowance studies to determine whether there was a 10% or more change in utility costs, we were unable to gather backup documentation from the PHA to analyze the utility costs. Effect: Due to the inability to determine the amount of change in utility costs, the PHA may have implemented inaccurate utility allowances which may have resulted in incorrect HAP payments. Recommendation: We recommend that the Authority list the required procedure on their annual calendar to verify that the utility rate data is analyzed, documented, and change as necessary. Documentation must include the comparison of the rates of the established utility rates to the current utility rates and the percent of change. Response: BPHA has already engaged a qualified third-party vendor to assist with the analysis and update of the Utility Allowance schedule to ensure compliance with HUD requirements. We will ensure supporting documentation is maintained. Compliance will be monitored through internal control processes to ensure annual reviews are completed timely and properly documented.

2025-005 Failed Inspections – Housing Assistance Payment (HAP) Made After Failed Inspection Condition: Payment was not abated upon failed inspection for non-life threatening condition. Additionally, one file out of a sample of six could not be located (see related finding 2025-003). Criteria: Unit inspections failing to meet Housing Quality Standards (HQS) not corrected with 24 hours for life threatening deficiencies or within 30 calendar days for all other deficiencies require abatement of HAP or termination of HAP contract. Context: One tenant’s payment was processed subsequent to the failed inspection. Effect: HAP payment processed in subsequent month resulting in overpayment. Recommendation: We recommend the Authority strengthen procedures to ensure HAP payments are properly abated upon failed inspection. Response: BPHA will implement procedures to ensure Housing Assistance Payments (HAP) are properly abated for units failing inspection. Failed inspection results will be documented and communicated to the appropriate staff prior to HAP processing. Periodic management reviews will be conducted to reconcile failed inspections to ensure abatements are timely, accurate, and properly documented.

2025-006 New Admissions – Missing Signed Housing Assistance Payment (HAP) Contract Condition: Signed HAP contract missing from one file. Additionally, two files out of a sample of ten could not be located (see related finding 2025-003). Criteria: HUD regulations require PHA’s to collect and maintain a signed HAP contract with the landlord to provide assistance under the voucher program. Context: The Authority could not locate the signed HAP contract although an unsigned copy was maintained in the file. Effect: The Authority is out of compliance with HUD requirements. Additionally, the lack documented evidence of an agreement with the landlord increases the risk for unsupported or ineligible payments. Recommendation: We recommend the Authority strengthen procedures to ensure all tenant files include a signed HAP contract. Response: BPHA has initiated corrective actions to strengthen internal procedures to ensure all files include fully executed HAP contracts. A standardized file review process will be implemented that includes periodic file reviews to ensure all documents required are complete and included.

2025-007 HCV Tenant Files – Incomplete Files Condition: Tenant files were lacking required information. Additionally, five files out of a sample of twenty-five could not be located (see related finding 2025-003). Criteria: HUD regulations require PHA’s to maintain complete and accurate tenant files which include tenant applications, executed leases and HAP contracts. Context: Several files were missing information related to applications, leases and in one instance a HAP contract. Effect: The Authority is out of compliance with HUD requirements. Additionally, incomplete files increase the risk of unsupported HAP payments. Recommendation: We recommend the Authority strengthen controls over tenant file management to ensure all required documentation is maintained. Response: See response for finding 2025-006

Condition: The Authority failed to substantiate the rate difference incurred in the current fiscal year. Criteria: Per 24 CFR section 982.517, the Authority 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% or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Context: While reviewing the utility allowance studies to determine whether there was a 10% or more change in utility costs, we were unable to gather backup documentation from the PHA to analyze the utility costs. Effect: Due to the inability to determine the amount of change in utility costs, the PHA may have implemented inaccurate utility allowances which may have resulted in incorrect HAP payments. Recommendation: We recommend that the Authority list the required procedure on their annual calendar to verify that the utility rate data is analyzed, documented, and change as necessary. Documentation must include the comparison of the rates of the established utility rates to the current utility rates and the percent of change. Response: We will establish processes to gather utility information to be used to support our conclusion as to whether utility allowances have varied by more than 10%.

2024-003 Contract Rent Reasonableness Condition: The Authority failed to substantiate that contract rents are reasonable for new admissions. Criteria: Per 24 CFR section 982.4, the Authority must determine and the document that the rent to an owner is reasonable at the initial leasing. Context: From our sample 13 new admissions, six files indicated that rent was not considered to be reasonable compared to the existing data in the software system. Effect: Without the ability to verify that the contract rent amounts are reasonable, a potential exists for HAP payments to be higher than permitted. Recommendation: We recommend that the Authority contact their software provider to determine whether there is an option to update the contract rent amounts to permit a better rent reasonable comparison. Otherwise, the Authority will need to review their procedures to determine a new approach to determine that new contract rents are reasonable. Response: All HAP payments are considered reasonable. We will implement processes to ensure that current rent data is entered into the software system so that rent reasonableness can be calculated correctly.