West Valley Housing Authority

US Department of Housing and Urban Development Direct Award Program Name Housing Choice Voucher; Mainstream Voucher "Internal Control" Significant Deficiency N Special Tests ALN(s) 14.871; 14.879 2025-001 Housing Quality Standards Inspection/HQS Enforcement Criteria The PHA must inspect the unit leased to a family at least bi-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 §§982.405, 983.103). Additionally, 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. 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). Condition During our audit, we identified four (4) failed HQS with Life Threatening issues based on the Authority's admin plan that did not receive a pass inspection within the required 24 hour time frame. Additionally, we found 2 units that were not inspected within the biennially period. Context The HQS population was 148 failed inspection. We selected a sample of 14 inspection and identified of those 14 reviewed 4 did not obtain a re-inspection pass within the criteria noted above and no rent abatement process was enforced on landlords. The HQS inspection population was all HAP payments for the year, and we selected a sample of 40 to test. Out of the 40 HAP payments tested, we identified 2 that were not inspected within the biennial requirement. Cause The non-compliance appears to stem from oversight or procedural lapses in the enforcement of HQS within the Housing Voucher Cluster program. This may be due to inadequate training, monitoring, or failure to adhere to established protocols. Effect This non-compliance undermines the integrity of the Housing Choice Vouchers Program and may lead to tenants living in substandard conditions. It also represents a risk of improper use of federal funds and can impact the credibility and effectiveness of the program. Recommendations Implement more stringent procedures for monitoring HQS compliance, including timely reinspection and enforcement of HAP abatement or voucher cancellation. Enhance training for staff involved in the HQS process to ensure a thorough understanding of compliance requirements. Establish a system of regular audits to identify and rectify lapses in HQS enforcement promptly. Questioned Costs The exact monetary impact needs further investigation to determine the amount of HAP that should have been abated for the period of non-compliance. Management Views The auditee acknowledges the deficiency in enforcing Housing Quality Standards (HQS) as highlighted in the finding. In response to this issue, the management commits to implementing a comprehensive Corrective Action Plan.

CORRECTIVE ACTION PLAN -For FY 2025 Audit Finding FINDING: 2025-001-ALN 14.871 & 14.879: U.S. Department of Housing and Urban Development’s (HUD’s) Section 8 Housing Choice Voucher (HCV) Program & Housing Quality Standards Inspection/HQS Enforcement CRITERIA: 24 CFR 982.405 & 983.103 require units leased, under the HCV Program, to be inspected at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. CONDITION: During the audit, three (3) failed HQS inspections, with life threatening issues as defined by the WVHA’s Administrative Plan, was found that did not receive a pass in conformance with the Criteria noted above and no HAP abatement process was enforced. Additionally, two (2) HCV units were found to have not been inspected at least biennially. PLAN FOR CORRECTION: Inspection Protocols- With the limitation of time imposed by the 24-hour remedy period, staff were calling and/or emailing the landlords as soon as they noted a Life, Health & Safety deficiency. Inspection staff have been informed that all Life Health and Safety deficiencies will immediately trigger a letter to the landlord (with a copy to the HCV caseworker) stating that Housing Assistance Payments will be placed in abatement and the HCV caseworkers will perform such abatement action as soon as the 24-hour period has elapsed (unless informed by the inspector that the property has subsequently corrected the deficiencies). Documentation- Physical inspection records will be provided to each HCV caseworker and be added to the tenant household’s HCV file within 24 hours of the inspection. HCV caseworkers are required to ensure all inspection documentation is properly located within each HCV file and such documentation is in accordance with the program’s rules and regulations. CONTACTS FOR PLAN: Cheryl Slagle – Housing Programs Manager Ph. (503) 623-8387 Ext. 328 cslagle@wvpha.org Christian Edelblute - Executive Director Ph. (503) 623-8387 Ext. 314 cedelblute@wvpha.org

2024-001

Program Name Housing Choice Vouhcer; Mainstream Voucher Internal Control Significant Deficiency N Special Test and Provisions ALN(S) Number 14.871;14.879 2024-001 Housing Quality Standards Inspection/HQS Enforcement Criteria The PHA must inspect the unit leased to a family at least bi-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 §§982.405, 983.103)). Additionally, 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. 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). Condition During our audit, we identified three (3) failed HQS with Life Threatening issues based on the Agency's admin plan that did not receive a pass inspection within the required 24 hour time frame. Context The HQS population was 76 failed inspection. We selected a sample of 8 inspection and identified of those 8 reviewed 3 did not obtain a re-inspection pass within the Criteria noted above and no rent abetment process was enforce on landlord. Cause Controls over compliance associated with the Authority’s grants of federal funds are inadequate. Effect The Authority is non‐compliant with the federal regulations over this federal program, this could potentially result in operating and financial penalties. Recommendations We suggest the Authority structure a system capable of properly overseeing compliance with regulations relative to these grants as well as maintaining more accurate and complete documentation of adherence to compliance. Management Views Management agrees, See Corrective Action Plan

CORRECTIVE ACTION PLAN -For FY 2024 Audit Findings FINDING: 2024-001-CFDA 14.871 & 14.879: U.S. Department of Housing and Urban Development’s (HUD’s) Section 8 Housing Choice Voucher (HCV) Program & Housing Quality Standards Inspection/HQS Enforcement CRITERIA: 24 CFR 982.405 & 983.103 require units leased, under the HCV Program, to be inspected at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. CONDITION: During the audit, three (3) failed HQS inspections, with life threatening issues as defined by the WVHA’s Administrative Plan, were found that did not receive a pass in conformance with the Criteria noted above and no HAP abatement process was enforced. PLAN FOR CORRECTION: Staffing- The West Valley Housing Authority created a new position of ‘Inspector’ and hired a candidate with a start of employment on January 6, 2025. This action consolidates the HCV HQS inspection function to one dedicated staff member as opposed to the two HCV Caseworkers who had been performing this function (along with their regular case work duties). Inspection Protocols- With the limitation of time imposed by the 24-hour remedy period, staff were calling the landlords as soon as they noted a Life, Health & Safety deficiency. Inspection staff have been informed that all communications (including phone calls) need to be documented in writing and a final inspection needs to be conducted to verify that the deficiencies have been corrected, and the inspection has passed. CONTACTS FOR PLAN: Cheryl Slagle – Housing Programs Manager Ph. (503) 623-8387 Ext. 328 cslagle@wvpha.org Christian Edelblute - Executive Director Ph. (503) 623-8387 Ext. 314 cedelblute@wvpha.org

Criteria: Eligibility guidelines stipulate the Housing Authority must determine income eligibility of the family or individual and, based on the annual income and other factors, calculate the housing assistance payment. Internal controls should be present to monitor this process. Condition: Adequate supervision and review is not provided over personnel determining eligibility and calculating the housing assistance payment. Cause: Administration did not develop and implement monitoring of eligibility determination and housing assistance payment calculations. Effect: Individuals and families not meeting the eligibility thresholds could be admitted to the program. Housing assistance payment calculations could be incorrect. Questioned Costs: None Recommendations: The Housing Authority should implement internal controls to better monitor eligibility and housing assistance payment calculations. Management's Response: These issues have been the result of an ongoing issue with a caseworker not paying attention to detail in the exercise of their work. This particular caseworker has left their employment with out agency as of the beginning of June 2021. Management is in the process of reviewing all files within this caseworker's caseload and will be working with the incoming replacement to ensure all calculations have been conducted in accordance with external regulation and internal policies and procedures.

PLAN FOR CORRECTION: File Review- Each file, case managed by the prior caseworker, is being reviewed to ensure the proper procedures have been followed, documentation has been established, and calculations have been performed in accordance with program regulations. This work is being performed by the Housing Programs Manager and is also serving as a training tool for the new staff member as to what errors to avoid in the performance of their case management. Staffing- The process of initial eligibility review has been assigned to one person for our Section 8 program; thus, concentrating the focus on this critical process and allowing for direct correction of errors or omissions being found in the manner through which this staff person is establishing calculations, performing verifications, and etcetera. This position being responsible for the initial eligibility process has worked in freeing up time for the Section 8 Caseworker/Inspectors and Housing Program Manager; allowing them to provide more oversight / supervisory review of the process, as opposed to having a full load of eligibility work along with the other, regular duties of which these positions are responsible for. Quality Control Sampling- The Housing Programs Manager, or other designee, will conduct a thorough review of minimum sample of files on a monthly basis, to ensure consistency amongst all case files. The sample size shall mirror the sample size requirements set forth in the Section 8 Management Assessment Program (SEMAP). A standardized review form is used to document any errors due to incomplete, unverifiable, or incorrect information and/or calculations. Staff, found responsible for any errors, will be held accountable to make appropriate corrections. All corrections will then be verified by the person performing the quality control review. If a pattern of errors is apparent, additional training will be scheduled for offending staff; or, if errors appear to be due to poor job performance (or indolence), staff will be properly disciplined. We did experience an issue with apparent indolence on behalf of one our caseworkers and they have moved on from employment with our agency as of June 2021.

2019-002

Criteria: Eligibility guidelines stipulate the Housing Authority must determine income eligibility of the family or individual and, based on annual income and other factors, calculate tenant rent. Internal controls should be present to monitor this process. Condition: Adequate supervision and review is not provided over personnel determining eligibility and calculating tenant rent. Cause: Administration did not develop and implement monitoring of eligibility determination and tenant rent calculations. Effect: Individuals and families not meeting the eligibility thresholds could be admitted to the program. Tenant rent calculations could be incorrect. Questioned Costs: None Recommendations: The Housing Authority should implement internal controls to better monitor eligibility and tenant rent calculations. Management?s Response: As a result of previous findings, management established the implementation of quality control procedures requiring the Housing Programs Manager, or other designee (I.e. third-party contractor, Administrative Analyst, or Executive Director) to thoroughly review a minimum sample of files on at least a quarterly basis. Sample size has previously been determined in accordance with the minimum sample size requirements outlined in the Section 8 Management Assessment Program (SEMAP) with the ?universe?, or whole, being those files involved in eligibility reviews, and/or the calculation of tenant rent, during the period. Due to the recurrence of this finding, it is obvious the sampling is inadequate and too many errors are going unchecked. Management is in the process of revising job descriptions and classifications as a result of a staff member recently retiring and the need to refine/streamline our operations under the prospect of repositioning our Public Housing assets under the Rental Assistance Demonstration (RAD). The process of initial eligibility review will be predominantly assigned to one person for Public Housing; thus, concentrating the focus on this critical process and allowing for direct correction of errors or omissions being found in the manner through which this staff person is establishing calculations, performing verifications, and etcetera. This position becoming responsible for the eligibility process will also free up time for the Property Managers and Housing Program Manager to provide more supervisory review of the process, as opposed to having a full load of eligibility work along with the other duties of which these positions are responsible for. The person filling this position will be trained in proper protocols and not bring forward incongruencies from previous training, job knowledge, or previous management. Management will ensure a basic review of all files is completed prior to being filed away, as opposed to such a limited sample as has previously been reviewed.

Staffing Change- The process of initial eligibility review has been assigned to one person for Public Housing; thus, concentrating the focus on this critical process and allowing for direct correction of errors or omissions being found in the manner through which this staff person is establishing calculations, performing verifications, and etcetera. This position becoming responsible for the eligibility process will also free up time for the Property Managers and Housing Program Manager to provide more supervisory review of the process, as opposed to having a full load of eligibility work along with the other duties of which these positions are responsible for. The person filling this position will be trained in proper protocols and not bring forward incongruencies from previous training, job knowledge, or previous management. Quality Control Sampling- The Housing Programs Manager, or other designee, will conduct a thorough review of minimum sample of files on at least a quarterly basis. The sample size shall mirror the sample size requirements set forth in the Section 8 Management Assessment Program (SEMAP). A standardized review form shall document any errors due to incomplete, unverifiable, or incorrect information and/or calculations. Staff, found responsible for any errors, will be held accountable to make appropriate corrections. All corrections will then be verified by the person performing the quality control review. If a pattern of errors is apparent, additional training will be scheduled for offending staff; or, if errors appear to be due to poor job performance (or indolence), staff will be properly disciplined.

2018-001

Criteria: Eligibility guidelines stipulate the Housing Authority must determine income eligibility of the family or individual and, based on the annual income and other factors, calculate the housing assistance payment. Internal controls should be present to monitor this process. Condition: Adequate supervision and review is not provided over personnel determining eligibility and calculating the housing assistance payment. Cause: Administration did not develop and implement monitoring of eligibility determination and housing assistance payment calculations. Effect: Individuals and families not meeting the eligibility thresholds could be admitted to the program. Housing assistance payment calculations could be incorrect. Questioned Costs: None Recommendations: The Housing Authority should implement internal controls to better monitor eligibility and housing assistance payment calculations. Management?s Response: As a result of previous findings, management established the implementation of quality control procedures requiring the Housing Programs Manager, or other designee (I.e. third-party contractor, Administrative Analyst, or Executive Director) to thoroughly review a minimum sample of files on at least a quarterly basis. Sample size has previously been determined in accordance with the minimum sample size requirements outlined in the Section 8 Management Assessment Program (SEMAP) with the ?universe?, or whole, being those files involved in eligibility reviews, and/or the calculation of tenant rent, during the period. Due to the recurrence of this finding, it is obvious the sampling is inadequate and too many errors are going unchecked. There is a disconnect between the current caseworkers and their understanding of how this process is to be conducted. Management is in the process of revising job descriptions and classifications as a result of a staff member recently retiring and the need to refine/streamline our operations under the prospect of repositioning our Public Housing assets under the Rental Assistance Demonstration (RAD). The process of initial eligibility review will be predominantly assigned to one person for our Section 8 program; thus, concentrating the focus on this critical process and allowing for direct correction of errors or omissions being found in the manner through which this staff person is establishing calculations, performing verifications, and etcetera. This position becoming responsible for the eligibility process will also free up time for the Section 8 Caseworker/Inspectors and Housing Program Manager to provide more supervisory review of the process, as opposed to having a full load of eligibility work along with the other, regular duties of which these positions are responsible for. The person filling this position will be trained in proper protocols and not bring forward incongruencies from previous training, job knowledge, or previous management. Management will ensure a basic review of all files is completed prior to being filed away, as opposed to such a limited sample as has previously been reviewed.

Staffing Change- The process of initial eligibility review has been assigned to one person for our Section 8 program; thus, concentrating the focus on this critical process and allowing for direct correction of errors or omissions being found in the manner through which this staff person is establishing calculations, performing verifications, and etcetera. This position becoming responsible for the eligibility process will also free up time for the Section 8 Caseworker/Inspectors and Housing Program Manager to provide more supervisory review of the process, as opposed to having a full load of eligibility work along with the other, regular duties of which these positions are responsible for. The person filling this position is being trained in proper protocols and is new to our agency / this field, so they will not bring forward incongruencies from previous training, job knowledge, or previous management. Quality Control Sampling- The Housing Programs Manager, or other designee, will conduct a thorough review of minimum sample of files on at least a quarterly basis. The sample size shall follow the sample size requirements set forth in the Section 8 Management Assessment Program (SEMAP). A standardized review form shall document any errors due to incomplete, unverifiable, or incorrect information and/or calculations. Staff, found responsible for any errors, will be held accountable to make appropriate corrections. All corrections will then be verified by the person performing the quality control review. If a pattern of errors is apparent, additional training will be scheduled for offending staff; or, if errors appear to be due to poor job performance (or indolence), staff will be properly disciplined.

2018-002

Criteria: 24 CFR ? 982.507 requires the Housing Authority re-determine reasonable rent before any increase in the rent to owner occurs. Condition: Tenant file did not have documentation that a redetermination of reasonable rent occurred prior to the increase in rent. Cause: Tenant files did not include documentation to support the determination that rent charged by the owner was reasonable. Effect: Unreasonable rent could be used in the HAP calculation resulting in overpayment of benefit. Questioned Costs: None Recommendations: The Authority should maintain documentation to support the determination that rent is reasonable. Management?s Response: Management has become aware of this deficiency in how each caseworker is documenting their performance of a rent reasonable review. Rent reasonable reviews are an available feature in our software system and we have been diligent about getting every unit built into the database. It has become known that staff have not been following through with the printing out, or documenting of, the rent reasonableness review in the paper file. This is a deficiency that will not be tolerated and each file will be reviewed to ensure such documentation is being properly recorded. Staff found guilty of failing to perform this process, and properly document it, will be disciplined in order to correct such behavior.

File Review, Counseling, and/or Reprimand- Each file will be reviewed to ensure a rent reasonable review is being conducted and properly recorded in the file. Staff found guilty of failing to perform this process, and properly document it, will be disciplined in order to correct such behavior.

Criteria: 24 CFR ? 982.517 requires the Housing Authority utilize utility allowance schedules in calculating housing assistance payments. Condition: The utility allowance calculated was incorrect. Cause: Inaccurate calculations of utility allowances led to underpayment of housing assistance payments. Effect: Incorrect calculations of utility allowances could lead to inaccurate calculations of housing assistance payments. Questioned Costs: None Recommendations: The Authority should correctly calculate utility allowances. Management?s Response: Utility allowances are reviewed, and updated as necessary, on at least an annual basis. The allowances are accurate, but staff have not been diligent in ensuring the right allowances are applied to each instance. It has been found that errors are being made in which utilities are being considered based upon the type of utility, location of rental unit, or landlord provisions. This is a deficiency that will not be tolerated and each file will be reviewed to ensure such documentation is being properly recorded. Staff found guilty of failing to accurately perform this process, and properly document it, will be disciplined in order to correct such behavior.

File Review, Counseling, and/or Reprimand- Each file will be reviewed to ensure the proper utility allowances are being used for the type of dwelling, its location, and tenant paid utilities. Staff found guilty of failing to perform this process, and properly document it, will be disciplined in order to correct such behavior.

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2017-001

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