HomeMy WebLinkAbout20050880.tiff QW'PZMENTppy0`m
U.S. DEPARTMENT OF HOUSING
+ *t AND URBAN DEVELOPMENT
°°q oe ROCKY MOUNTAIN, DENVERelAN oEgE`
167O Broadway
DENVER, COLORADO 80202-4801
Office of Public Housing -
NOV 1 6 2005
Mr. Tom Teixeira
Executive Director
Greeley Housing Authority
P.O.Box 130
Greeley, CO 80632-0008
Dear Mr. Teixeira:
During the week of August 8 — 12, 2005,members of my staff visited the Greeley and
Weld County Housing Authorities(GHA&WCHA) for a follow-up review of the HUD Office
of Investigator General (OIG) audit findings issued Tune 22, 2004. The audit contained two
findings with recommendations required to close the findings. A summary of the findings and
recommendations closed as well as any corrective actions still needed is enclosed.
In summary,Recommendations 1A.1-6, 1B, 1C, 1D, and 2A. 1-2 are now closed.
Recommendations 1E,2B, and 2C are still open and the closure date is June 30, 2006. We
appreciate the efforts on behalf of the GHA and WCHA in resolving these issues. We sincerely
appreciate the responsiveness of GHA and WCHA in performing the corrective actions and the
cooperation of GHA and WCHA's employees in working with my staff to facilitate these closing
actions.
If you have questions regarding the above, or, if we may be of assistance,please contact
Ms. Charlotte Keator,Public Housing Revitalization Specialist or Ms. Nonda Elder,Financial -
Analyst, at(303) 672-5372, extension 5364 or 5351,respectively.
Sincerely, •
•
Ann Roman
Acting Director
Office of Public Housing
cc:
BOC Greeley Housing Authority
BOC Weld County Housing Authority
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Finding No. 1 - Controls Over Low-Rent(LR) Housing Occupancy Activities Need to Be
Improved.
GHA must follow and enforce their Admissions and Continued Occupancy Policy:
Recommendation
1A.1 —GHA must ensure Social Security Card and/or related documents are properly obtained
for all family members and documented.
GHA must require each assisted applicant to submit his/her complete and accurate Social
Security Number and other tenant eligibility documentation needed for each household member.
GHA must follow the Social Security Number Verification procedures where needed.
The GHA must complete the tenant documentation review of the files targeted during the HUD
OIG review and obtain any missing documentation to complete the file. The GHA must continue
to review all other tenant files for completeness. We will work with OIG to get the required
information to you so you can complete corrective action.
•
Corrective Action Taken
In our letter dated January 20,2005, OPH instructed GHA to follow and enforce their ACOP.
During the week of August 8, 2005, OPH reviewed and verified, (via a sampling of tenant files,
that included a review of the files reviewed by OIG)that GHA is following their ACOP and that
GHA's tenant files contained copies of the tenant's Social Security Card and/or related
documentation needed for each household member. All of the twenty-five files reviewed
contained eligibility documentation and the families were eligible to participate in the HUD
funded Low Rent (LR)hosing program. One of the files reviewed did not contain a copy of the
social security card,however, the file contained a copy of her social security benefits letter and
she was over 62 years of age. This was adequate documentation for tenant identification
verification. OPH asked GHA staff to work with the client to obtain a social security card.
Based on the above,we consider Recommendation 1A.1 closed.
Recommendation
1A.2—GHA must ensure all necessary citizen eligibility forms are obtained for all family
members and properly documented. This would ensure the tenant rents are being correctly
calculated.
The GHA must obtain citizenship or eligible immigration status documentation supporting the
eligibility of each family member. The GHA staff must also obtain the required declaration
statement identifying the citizenship or eligible immigration status of all family members.
The GHA must prorate the rent of families with members who do not submit evidence to
establish their citizenship or eligible immigration status.
GHA must review and recalculate the tenant rents that were not properly prorated as indicated by
the files reviewed by HUD OIG.
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The GHA must continue to review all other tenant files to ensure all tenant rents are properly
pro-rated and that all the required documentation is in the tenant's file.
OPH will review and verify, on-site,that GHA's tenant files contain all eligibility documentation
and all families are eligible to participate in the HUD- funded LR Housing Program.
Corrective Action Taken
In our letter dated January 20,2005, OPH informed the GHA that they must obtain citizenship or
eligible immigration status including a signed declaration statement. During the week of
August 8, 2005, OPH reviewed and verified, via a tenant file sampling,that GHA's tenant files
contained all eligibility documentation and all the tenants were eligible to participate in the HUD
funded LR housing program. All files reviewed contained the certification of citizenship or a
signed non-contending form. All non-eligible household members' income was included in the
total family annual income and the prorating of the total tenant payment was correct. OPH
reviewed 25 tenant files to ensure tenant rental payments were being calculated correctly. Based
on the above,we consider Recommendation 1A.2 closed.
Recommendation
1A.3—GHA must ensure rental payments for tenants participating in the Earned Income
Disregard Program are being properly calculated and charged to the tenants.
GHA must verify that all tenants participating in the Earned Income Disregard Program are
eligible to participate and are paying the correct rental payment. The GHA must continue to
review all other tenant files to ensure all tenants who are eligible to receive the Earned Income
Disregard are allowed the opportunity to participate;that the rents are properly calculated; and all
required documentation is in the tenant's file.
GHA must recalculate the tenant rents that were not properly calculated and begin immediately
charging the correct tenant rent. We will work with OIG to get the required information to you
so you can complete this corrective action.
OPH will review and verify on-site,that GHA's tenant files contain all required Earned Income
Disregard documentation and families eligible to participate in the program are receiving the
disregard.
Corrective Action Taken
In our letter dated January 20, 2005, OPH instructed GHA to ensure rental payments for tenants
participating in the Earned Income Disregard Program are being calculated and charged correctly.
During the week of August 8, 2005, OPH reviewed and verified,via a tenant file sampling, that
GHA's tenant files contained all the required Earned Income Disregard documentation and
tenants participating in the program were eligible and the tenant rental payments were calculated
correctly. Based on the above, we consider Recommendation 1A.3 closed.
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Recommendation
1A.4—GHA must ensure waiting lists are being properly established and maintained and GHA
tenants are being placed in housing in conformity with the GHA adopted Admissions and
Continued Occupancy Policy(ACOP).
GHA must review all LR applicants to ensure they are in their proper position on the waiting
lists. OPH will review and verify on-site, that GHA's waiting list is being administrated in
accordance with its ACOP. This will include ensuring that tenants are properly selected.
Corrective Action Taken
In our letter dated January 20,2005, OPH instructed GHA to ensure waiting lists are being
properly established and maintained and GHA's tenants are being placed in housing in
conformity with the GHA adopted ACOP. OPH reviewed GHA's waiting list for January 2005
through August 2005 and other reports that are generated to provide additional tracking. OPH
verified that applicants are being housed based on the order their name appears on the waiting
list. OPH staff interviewed Ms. Karen O'Connor, GHA's Occupancy Specialist, to determine
that selections from the waiting list were in accordance with local housing preferences
established by the ACOP. OPH also reviewed applications submitted to GHA and GHA's log
that tracks information related to the waiting list(i.e., date that the applicants are sent letters
when they approach the top of the waiting list;the date posted that the application is completed
and returned; date of the lease up; date applicant is removed from the waiting list for failure to
respond to GHA's notice; date applicant is denied housing because of criminal background, etc.)
Based on our review of GHA's records, we have determined GHA is in compliance with its
ACOP and procedures for selecting applicants for housing assistance. Based on the above,we
consider Recommendation 1A.4 closed.
Recommendation
1A.5-OPH will require the GHA to review all tenant repayment agreements to ensure tenant
repayment agreements are being properly implemented and consistently enforced in conformity
with the GHA adopted procedures.
OPH will review and verify, via a tenant file sampling,that GHA's tenant repayment agreements
are being enforced in accordance with GHA's ACOP (including requiring payments and
imposing sanctions for non-payment).
Corrective Action Taken
1A.5—Tenant repayment agreements are being properly implemented and consistently enforced
in conformity with the GHA adopted procedures.
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While on-site during the week of August 8-12, 2005 the OPH staff reviewed all tenant repayment
agreements to ensure that all were properly implemented and consistently enforced in conformity
with the GHA adopted procedures. All repayment's on file at GHA were reviewed. On
August 8, 2005, letters of overdue charges were sent to the tenants. These letters identified what
the charges were for and the amount due. OPH staff also reviewed the"Monthly Rental Register
—Tenant Detailed listing all Tenant—Charges"to compare amounts owed with the letters sent on
August 8, 2005. The comparison showed that the repayment agreements were properly
implemented and consistently enforced according to the GHA policy and procedures. Based on
the above information we consider this Recommendation 1 A.5 closed.
1A.6—Security deposits are being uniformly and consistently charged to incoming tenants in
accordance with the GHA Admission and Continued Occupancy Policy. OPH will require the
GHA to review all security deposits and leases to ensure the correct security deposit was written
in the lease at the time of admittance into the Low Rent program. GHA must correct any
discrepancies and correct the lease. The tenant security ledger must be corrected to reflect the
Corrective Action Taken
1A6-During our on-site visit the week of August 8-12, 2005, OPH verified that GHA's security
deposits were being uniformly and consistently charged to the incoming tenants.
OPH staff compared the security deposit ledger with the tenant leases. We found inconsistencies
between the two documents. The OPH staff reviewed tenant files to determine the correct
security deposits charged to the tenant at the time the lease was signed. The tenant files were
then compared with the tenant deposit ledger to verify that both amount were the same.
Olga Sanchez' (#19 in the Security Deposit Listing)lease was reviewed. At the time of
occupancy the security deposit amount was $200.00. While reviewing the file HA staff
inadvertently wrote$300 at recertification for the Security Deposit. During our review Angie
Shafranek, Public Housing Manager,prepared and sent a letter to Ms. Sanchez with a correct
lease showing the correct Security Deposit amount as$200.00.
Realy Vasquez' (#9 in the Security Deposit Listing)original lease showed the security deposit as
$200.00 in 2001. On the 2003 and 2004 recertification the deposit was shown as $300.00 by
mistake. A letter was sent to the tenant to correct the deposit to$200.00.
Based on the above information we consider this Recommendation 1A.6 closed.
Recommendation
1B -The GHA must review all current LR tenant files to ensure all necessary citizenship and
tenant immigration status documentation is in the file. If the tenant files are missing the required
documentation the tenant rent must be prorated for families whose members have not submitted
evidence of eligibility.
OPH will verify, on-site,that family members are eligible to participate in the HUD funded LR
Housing Program.
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Corrective Action Taken
In our letter dated January 20, 2005, OPH instructed GHA to review all current Low-Rent tenant
files to ensure all necessary citizenship and resident immigration status documentation was in the
file. During the week of August 8, 2005, OPH reviewed and verified,via a tenant file sampling,
that GHA's tenant files contain all eligibility documentation and all tenants were eligible to
participate in the HUD funded Low Rent Hosing Program. All files contained the certification of
citizenship or a signed non-contending form. All non-eligible household members' income was
included in the total family annual income and the prorating of the total tenant payment was
correct. OPH reviewed 25 tenant files to ensure tenant rental payments were being calculated
correctly. Based on the above,we consider Recommendation 1B closed.
Recommendation
1C - GHA must review all Low Rent files for tenants that are participating in the Earned Income
Disregard Program to determine that the Earned Income Disregard was calculated correctly and
adjust rents where there were errors.
GHA must review all tenant files to verify tenant eligibility to participate in the Earned Income
Disregard Program.
OPH will review,on-site, a sampling of GHA tenant files to ensure the Earned Income Disregard
Program was administered correctly and that only the increase in earned income of a participant
was used in calculating the disregard.
The GHA's employees administering the Earned Income Disregard Program must receive
training on the program. The GHA must certify that the employees administering the program
have been educated concerning the procedures/guidelines of the Earned Income Disregard
Program.
The GHA must correct the Earned Income Disregard Program letter that was sent to program
participants and adjust rents where there were errors.
Corrective Action Taken
In our letter dated January 20, 2005, OPH instructed GHA to review all Low Rent files for
tenants that are participating in the Earned Income Disregard Program to determine that the
Earned Income Disregard was calculated correctly and to adjust rents where there were errors.
During the week of August 8, 2005, OPH reviewed 25 tenant files and verified that GHA's
tenant files contain all required Earned Income Disregard documentation and families eligible to
participate in the program are receiving the disregard. Currently GHA has only 2 families that
qualify for the earned income disregard program. Based on the above,we consider the
recommended action to be closed for 1C.
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Recommendation
1D—The GHA must review all Low Rent housing tenants' files to determine if they are eligible
to participate in the Earned Income Disregard Program.
GHA must recalculate and submit for review the tenant's files reviewed by OIG staff to
determine eligibility to participate in the Earned Income Disregard Program.Upon OPH's
determination of eligibility and re-calculation of the Earned Income Disregard a revised
restitution of undercharged total tenant payments will be determined. GHA must correct the
tenant files and repay the undercharged tenant rents from a non-federal funding source.
OPH will review on-site the Low Rent files to ensure GHA is correctly calculating total tenant
payments and that tenant participants who were offered the Earned Income Disregard were
eligible for the program.
If OPH calculates a different amount of undercharged total tenant payments, OPH will inform
OIG of the revised amount and a copy of GHA's plan for recovering that amount will be
submitted to OIG. Additionally documentation will be provided to OIG indicating the
unsupported cost has been recovered or otherwise cleared.
Corrective Action Taken
In our letter dated January 20, 2005, OPH instructed GHA to review all LR housing participants
to determine if they are eligible to participate in the Earned Income Disregard Program. During
the week of August 8,2005, OPH reviewed 25 tenant files and verified that GHA's tenant files
contain all required Earned Income Disregard documentation and families eligible to participate
in the program were receiving the disregard. OPH agrees with the OIG finding that one family's
Earned Income Disregard had been incorrectly calculated,resulting in the family under paying
rental payments of$7,824. GHA has reimbursed the LR operating fund with a non-federal
source of funds. Based on the above,we consider Recommendation 1D closed.
Finding No. 2—Controls over the Section 8 Housing Choice Voucher Program Occupancy
Activities That Need to be improved,
Recommendation
2A.1 -The GHA and WCHA must follow and enforce their Administrative Plans. In particular
GHA and WCHA must ensure that required Social Security Cards and/or related documents are
properly obtained for all family members participating in the HCV program, and the Social
Security numbers are properly verified.
The GHA and WCHA must require each assisted applicant to submit their complete and accurate
Social Security Number and other participant eligibility documentation needed for each
household member.
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The GHA and WCHA must complete a Section 8 HCV participant documentation review of the
files targeted during the GIG review and obtain the proper documentation to complete the file.
The GHA and WCHA staff must continue to review all other participant files for completeness.
The GHA and WCHA staff must follow the Social Security Number verification procedures and
obtain documentation of the Social Security Number for each Section 8 HCV participant.
OPH will review a random sample of GHA and WCHA's Section 8 HCV files to ensure GHA
and WCHA have all required verification documentation.
Corrective Action Taken
In our letter dated January 20, 2005, OPH instructed GHA and WCHA to follow and enforce
their Section 8 Administrative Plans. In particular GHA and WCHA were instructed that required
Social Security Card and/or related documents must be properly obtained for all family members
participating in the HCV program, and that the Social Security numbers must be properly
documented. During the week of August 8, 2005, OPH reviewed and verified, via a tenant file
sampling,that GHA and WCHA's tenant files contained a complete and accurate Social Security
Card and/or related documentation needed for each household member. OPH reviewed 22
GHA's HCV files and 23 WCHA's HCV files. All the files reviewed contained eligibility
documentation and the families were eligible to participate in the HUD funded Section 8 housing
programs. Based on the above,we consider Recommendation 2A.1 closed.
Recommendation
2A.2 - The GHA and WCHA must obtain citizenship or eligible immigration status
documentation to support the eligibility of each member participating in the Section 8 HCV
program. The GHA and WCHA staff must also obtain the required declaration statement
identifying citizenship or eligible immigration status of all family members participating in the
program.
The GHA and WCHA must prorate the rent of families with members who do not submit
evidence or establish their citizenship or eligible immigration status.
The GHA and WCHA must review and recalculate the participant's family rent in the cases
where it was not properly prorated as indicated by the files reviewed by HUD GIG.
The GHA and WCHA must continue to review all other participant files to ensure all Housing
Assistance Payments and tenant portions of the rent are properly prorated and that all the required
documentation is in the Section 8 HCV participant's file.
The WCHA staff must review its calculation of 2003 administrative fees and report to HUD the
results of its review and any adjustments needed. WCHA must ensure that future administrative
fee calculations are correct and are properly documented.
OPH will review on-site participant file sampling,that GHA and WCHA's participant files
contain all eligibility documentation for all families that are eligible to participate in the HUD-
funded HCV program.
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Corrective Action Taken
In our letter dated January 20, 2005, OPH instructed GHA and WCHA to obtain citizenship or
eligible immigration status documentation to support the eligibility of each member participating
in the Section 8 HCV program. During the week of August 8, 2005, OPH reviewed and
verified, via a tenant file sampling,that GHA and WCHA Section 8 participant files contain all
eligibility documentation and all participants were eligible to participate in the HUD funded
Section 8 HCV Program. All files contained the certification of citizenship or a signed non-
contending form. All non-eligible household members' income was included in the total family
annual income and the prorating of the total tenant payment was correct. OPH reviewed 22 GHA
and 23 WCHA Section 8 participant files to ensure tenant rental payment were being calculated
correctly.
The WCHA states they operate in good faith regarding the administrative fee collection. They
are not able to make automatic changes to the calculations in their computer system for 2003
because it is a real time system designed to prohibit staff from going back and altering records in
an attempt to defraud the program. The WCHA has provided documentation of their revised
operating procedures to ensure they properly account for administrative fees. To further address
this fording the WCHA Section 8 Administrator has started maintaining a monthly computer
generated administrative fee calculation sheet,manually writing the name of the tenants who
were added or deleted from the program for which an administrative fee is due, and provide a
copy to the accountant for manual corrections in the accounting records at the end of the month.
These actions should help in eliminating problems associated with the charging of administrative
fees in the future. The OPH staff will further require computer generated administrative fee
calculation sheets for the fourth quarter months of October,November and December 2005.
Based on the above we consider Recommendation 2A.2 closed.
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