City of PittsburgState Government

SA2025-001: Suspension and Debarment Verification Not Documented – Significant Deficiency Assistance Listing Numbers: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: U.S. Department of Treasury Federal Award Identification Number: N/A Criteria Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition During testing of procurement transactions, we noted that debarment and suspension verification was not documented for one of the two procurements tested. Cause The City did not maintain sufficient documentation to demonstrate that the required debarment and suspension verification was performed prior to entering into the transaction. Effect Inability to demonstrate compliance with debarment and suspension requirements may result in questioned costs requiring repayment to federal agencies if the City enters into covered transactions with vendors that are subsequently identified as either suspended or debarred from participating in federally funded programs. Questioned Costs No questioned costs were identified. Recommendation We recommend that the City enhance its procedures to ensure that suspension and debarment verification is performed prior to contract award and that appropriate documentation is retained in the procurement file to support compliance with federal requirements. Management Response The City concurs with the finding. The required suspension and debarment verification was completed; however, the documentation retained did not meet federal standards. The City is currently updating procedures city-wide to ensure full SAM.gov documentation is retained and that suspension/debarment contract language is consistently applied.

Criteria: 24 CFR Section 982 requires recipients of Section 8 Housing Choice Vouchers to submit data on monthly leasing activities and costs for the program via mandatory Public Housing Authority (PHA) reporting through the Voucher Management System (VMS). The Department of Housing and Urban Development (HUD) reviews VMS data and uses the data for a variety of major functions, including budget formulation, utilization analysis and funding allocations. Condition: During the current year, the City underwent a monitoring review by the grantor related to the VMS data submitted by the City to HUD for the City’s Section 8 Housing Choice Voucher Program (Program) for the time period of December 1, 2021 through November 30, 2022. The purpose of the review was to validate the Unit Months Leased (UML) and related Housing Assistance Payment (HAP) expenses certified as accurate by the PHA. The grantor issued a letter dated March 6, 2023 detailing the results of the review. The monitoring review results included one finding and three concerns: Finding 1: Multiple HAP and unit months leased (UML) categories could not be validated, adversely affecting validation of total HAP and total UML. Concern 1: The portable vouchers administered UML and HAP could not be validated. Concern 2: Vouchers issued but not under HAP contract on the last day of the month could not be validated. Concern 3: The PHA did not report the number of project-based vouchers (PBVs) under an agreement to enter into a HAP contract and not under a HAP contract. Concern 4: The number of PBVs under HAP contract and leased/not leased; and the total PBV HAP expenses could not be validated. Effect: The Housing Authority is not in compliance with the requirements set forth by 24 CFR Section 982 regarding VMS reporting. Cause: The Housing Authority’s re-inspection delays discussed above were due to understaffing at the Housing Authority during fiscal years 2022 and 2023. Furthermore, the Housing Authority converted its Housing software during fiscal year 2022. During the data migration process, certain leasing and contract documents did not transfer into the new Housing software and the Housing Authority no longer had access to certain leasing and contract documents. Recommendation: Although the City responded to the findings in its April 6, 2023 letter to the grantor with corrective action plans, the City should revise its policies and procedures, where applicable, to ensure that all VMS reporting is in compliance with the grant requirements and CFR. In addition, the City should continue to work with HUD to ensure compliance with all goals identified in the corrective action plan provided to HUD. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Finding SA2022-001: Housing Quality Inspections Assistance Listing Number: 14.871 Assistance Listing Title: Section 8 Housing Choice Vouchers Program Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number and Year: CA060VO (2022) Criteria: 24 CFR Section 982 requires recipients of Section 8 Housing Choice Vouchers to inspect housing units for compliance with Housing Quality Standards (HQS). For units under a Housing Assistance Payment (HAP) contract that fail to meet HQS, the Housing Authority must require the owner to correct deficiencies within a specified period. Normal deficiencies of units should be corrected within thirty days of the initial failed inspection date, unless other circumstances occur. Life threatening deficiencies should be corrected within 24 hours of the initial failed inspection. Furthermore, if the Housing Authority does not verify the correction of the deficiency within sixty days of the failed inspection date, a termination notice for the contract will be issued and the HAP will be terminated. Condition: We tested thirteen failed HQS inspections in fiscal year 2022 and reviewed supporting documents for re-inspections to determine if deficiencies were corrected within the required periods for the units under the Housing Authority?s Section 8 Housing Choice Vouchers Program. During our review, we noted the following four deficiencies: 1. We noted two units that had failed inspections due to non-life threatening (normal) deficiencies on an initial inspection in November 2021. We noted that the Housing Authority had documentation of work orders to correct the units deficiencies in October 2022. However, the Housing Authority was unable to provide inspection documentation due to the fact that the Housing Authority?s legacy software with the documentation is no longer available. During fiscal year 2022, the Housing Authority converted the Housing software to a new program and the data migration did not provide the requested documents. 2. We noted four units that had failed inspections within the timeframe of November 2021 through January 2022. Although the Housing Authority inspection results letters indicated that a reinspection would occur a month later, we noted that the Housing Authority re-inspections were not completed until October 2022 for one unit, January 2023 for one unit and February 2023 for the remaining two units. 3. We noted two units that had failed initial inspections due to non-life threatening (normal) deficiencies on an initial inspection in November 2021 and January 2022, respectively. Although we noted that the Housing Authority worked with the tenants and reinspected the units, we noted that the repairs were not made until October 2022 and November 2022, respectively. We also noted that the Housing Authority did not abate the HAPs for the tenants after the sixty days lapsed from the initial failed inspections. 4. We noted two units that had failed initial inspections due to life threatening deficiencies from deficient smoke detectors, however, the Housing Authority did not maintain documentation that the follow up on the units? deficiencies occurred within 24 hours of the failed initial inspections to ensure the smoke detectors were operable. Effect: The Housing Authority is not in compliance with the requirements set forth by 24 CFR Section 982 regarding HQS inspections. Cause: The Housing Authority?s re-inspection delays discussed above were due to understaffing at the Housing Authority during fiscal year 2022. Furthermore, the Housing Authority converted Housing software during fiscal year 2022. As a result, during the data migration process, certain inspection documents did not transfer into the new Housing software and therefore, the Housing Authority does not have access to certain inspection documents. Questioned Costs: There are no known questioned costs for this finding and any potential questioned costs would be deminimus, based on the number of tenants who participate in the program and the dollar amount of Housing Choice Vouchers for Section 8 during fiscal year 2021-22. Identification As a Repeat Finding: No. Recommendation: We recommend that the Housing Authority develop procedures to ensure that re-inspections are performed timely and to ensure that life threatening deficiencies are corrected and re-inspected within 24 hours of the failed inspection. We also recommend that the Housing Authority terminate the HAP contract if a unit deficiency is not corrected within sixty days. Furthermore, we recommend that the Housing Authority maintain a system to backup data for documentation of all inspections performed. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

CFDA number: 14.871 CFDA Title: Section 8 Housing Choice Vouchers Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: CA-060 Criteria: 24 CFR part 982 details various rules and regulations of the Section 8 Housing Choice Voucher program. These regulations include specific program requirements. In addition, 2 CFR 2000.305(b)(9) requires that interest earned on federal advance in excess of $500 per year be returned to the federal government. Condition: During the current year, the City underwent a monitoring review by the grantor related the activities in the City?s Section 8 Housing Chose Voucher program. The specific purpose of the review includes reconciling net position balances reported by the City in recent periods, validating and analyzing administrative expenses, determining appropriateness of program expenditures, and confirming the availability of cash and investment sufficiency to support the net positions calculated. The grantor issued a letter dated September 28, 2020 detailing the results of the review. The monitoring review results included three findings: ? The first finding was related to the reporting of restricted net position and unrestricted net position account balances in the Voucher Management System (VMS). The letter stated that City staff incorrectly calculated and reported restricted net positions, unrestricted net positions, and cash account balances in the VMS from December 2017 through 2019. ? The second finding was related to the use of restricted net position in the Housing Assistance Payment Funds. As a result of the review, the grantor disallowed $297,856 of program expenditures incurred during the period December 2017 to December 2019 and demanded the City to reimburse the amount to the grantor. ? The third finding was related to interest earned on the Housing Assistance Payment Funds. Due to the first finding above, the grantor revised the City?s restricted net positions, unrestricted net positions, and cash account balances reported on the VMS for the period December 2017 to December 2019. Consequently, interest earned on federal advance during that period was recalculated, resulting in $21,189 of interest income that the City is required to return to the US Treasury. Cause: The condition above was caused by different interpretations, between the City and the grantor, of certain provisions stated on the CFR. The City is currently working with the grantor to arrive to a solution. Effect: If the City does not adhere to the requirements of 24 CFR part 982 and 2 CFR 2000.305(b)(9) on an ongoing basis to ensure continued compliance, expenditures incurred under the program may be deemed ineligible and need to be returned to the grantor. Questioned Costs: We question the $297,856 of costs incurred during the period December 2017 to December 2019 as noted on second finding above. Recommendation: Although the City responded to the findings in its October 28, 2020 letter to the grantor with corrective action plans, once a solution is reached with the grantor the City should revise its policies and procedures, where applicable, to ensure that all future grant program activities are in compliance with the provisions of the grant agreement and the CFR. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

CFDA number: 14.871 CFDA Title: Department of Housing and Urban Development Section 8 Housing Choice Vouchers Name of Federal Agency: Department of Housing Urban Development Criteria: 24 CFR Section 982 requires recipients of Section 8 Housing Choice Vouchers to inspect housing units for compliance with Housing Quality Standards (HQS). For units under a Housing Assistance Payment (HAP) contract that fail to meet HQS, the Housing Authority must require the owner to correct deficiencies within a specified period. Normal deficiencies of units should be corrected within thirty days of the initial failed inspection date, unless other circumstances occur. Life threatening deficiencies should be corrected within 24 hours of the initial failed inspection. Furthermore, if the Housing Authority does not verify the correction of the deficiency within sixty days of the failed inspection date, a termination notice for the contract will be issued and the HAP will be terminated. Condition: We selected nineteen failed HQS inspections in fiscal year 2019 and reviewed supporting documents for re-inspections to determine if deficiencies were corrected within the required periods for the units under the Housing Authority?s Section 8 Housing Choice Vouchers Program. During our review, we noted the following two deficiencies: 1. We noted one unit that had a failed initial inspection due to a non-life threatening (normal) deficiency on an initial inspection dated November 26, 2018. A second inspection for the unit was scheduled for December 10, 2019, in which the unit again failed. A third inspection for the unit was scheduled for January 1, 2019, which resulted in a no show by the tenant. A fourth inspection for the unit was scheduled for February 22, 2019, however the inspector did not show up to inspect the unit. A final inspection was completed on March 8, 2019, in which the unit passed. We also noted that the Housing Authority did not abate the HAP for the tenant after the sixty days lapsed from the initial failed inspection. 2. We noted four units that had failed initial inspections due to life threatening deficiencies from deficient carbon monoxide detectors, however, the Housing Authority did not follow up on the units? deficiencies within 24 hours of the failed initial inspection to ensure the detectors were operable. Effect: The Housing Authority is not in compliance with the requirements set forth by 24 CFR Section 982 regarding HQS inspections. Cause: The above was due to a City?s staff oversight for the failed inspection. Finding SA 2019-001: Re-Inspections for Units with Deficiencies (Continued) Questioned Costs: There are no known questioned costs for this finding and any potential questioned costs would be deminimus, based on the number of tenants who participate in the program and the dollar amount of Housing Choice Vouchers for Section 8 during fiscal year 2018-19. Identification as a repeat finding: Yes, since 2018. See Finding SA 2018-001. Recommendation: We recommend that the Housing Authority develop procedures to ensure that re-inspections are performed timely. Furthermore, we recommend that the Housing Authority terminate the HAP contract if a unit deficiency is not corrected within sixty days. We also recommend that the Housing Authority develop procedures to ensure that life threatening deficiencies are corrected and re-inspected within 24 hours of the failed inspection. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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