Issue Date May 31, 2006 Audit Report Number 2006-AT-1010 TO: John G. Niesz, Director, Office of Public Housing, 4HPH FROM: James D. McKay Regional Inspector General for Audit, 4AGA SUBJECT: The Orlando Housing Authority Did Not Ensure That All Section 8 Units Met Housing Quality Standards and Paid Excessive Subsidies for Some Units HIGHLIGHTS What We Audited and Why We audited the Orlando Housing Authority’s (Authority) Section 8 Housing Choice Voucher program as part of the Department of Housing and Urban Development (HUD), Office of the Inspector General’s (OIG) annual audit plan. We selected the Authority for review based on a Section 8 risk assessment we conducted. The audit objectives were to determine whether the Authority made Section 8 subsidy payments only for units that met housing quality standards and whether subsidy payments were limited to the amount allowed for the unit size authorized by each family’s composition. What We Found Of the 67 units inspected, 20 did not meet standards of which 8 units were in material noncompliance. This condition occurred because the Authority’s inspectors did not identify the unit deficiencies during their inspections or identified the conditions but did not report the units as being in noncompliance. Table of Contents As a result, the Authority paid $31,474 in ineligible subsidies for the 8 units, and we estimate the Authority will pay housing assistance payments of more than $1.14 million for units in material noncompliance with housing quality standards. The Authority paid $10,393 in excess housing assistance payments for 5 of 22 tenants housed in units larger than justified by the families’ composition. The improper voucher size occurred because the Authority did not always follow requirements to ensure that tenants are only issued Section 8 vouchers for the unit size authorized by their family composition. What We Recommend We recommend that the director of the Office of Public Housing require the Authority to abate Section 8 subsidies or terminate HAP contracts on all units that do not meet standards if the violations detected by our inspections are not corrected in a timely manner. The director should also require the Authority to improve its controls over the inspection process to ensure that inspectors properly identify and report all housing quality standards violations in the units they inspect. The recommended action is needed to prevent more than $1.14 million from being spent on units with material housing quality standards violations. We further recommend that the director require the Authority to repay $31,474 from nonfederal funds for ineligible housing assistance payments it made for the eight units with material violations. We also recommend that the director of the Office of Public Housing require the Authority to reimburse its program from nonfederal funds $10,393 for excess housing assistance payments for five overhoused tenants plus any additional amount paid until corrective action is taken. The director should also require the Authority to establish controls to ensure initial determination of the correct voucher size and to adjust tenant vouchers in a timely manner to reflect reported changes in family composition. The director should require the Authority to issue the correct size voucher to each overhoused tenant and ensure their subsidy amounts are properly calculated. For each recommendation without a management decision, please respond and provide status reports in accordance with HUD Handbook 2000.06, REV-3. Please furnish us copies of any correspondence or directives issued because of the audit. Table of Contents 2 Auditee’s Response We discussed the findings with the Authority and HUD officials during the audit. We provided a copy of the draft report to Authority officials on April 6, 2006, for their comments and discussed the report with the officials at the exit conference on April 14, 2006. The Authority provided its written comments to our draft report on April 26, 2006. The complete text of the Authority’s response, along with our evaluation of that response, can be found in appendix B of this report. The Authority also provided attachments with its response that are available for review upon request. Table of Contents 3 TABLE OF CONTENTS Background and Objectives 5 Results of Audit Finding 1: The Authority Paid Section 8 Subsidies for Some Units That Did Not 6 Meet Housing Quality Standards Finding 2: The Authority Paid Excess Subsidies for Five Overhoused Tenants 11 Scope and Methodology 13 Internal Controls 15 Appendixes A. Schedule of Questioned Costs and Funds to Be Put to Better Use 16 B. Auditee Comments and OIG’s Evaluation 17 4 BACKGROUND AND OBJECTIVES The Orlando Housing Authority (Authority) is a governmental agency created by the City of Orlando, Florida, in January 1938 pursuant to Chapter 421 of the Florida Statute. The Authority’s primary purpose is to develop, acquire, and operate safe, decent, sanitary, and affordable housing for low-income families in Orlando and Orange County, Florida. The U.S. Department of Housing and Urban Development’s (HUD) Jacksonville, Florida, Office of Public Housing is responsible for overseeing the Authority. The mayor of the City of Orlando appoints a seven-member board of commissioners to four-year terms to govern the Authority’s operations. The Authority’s executive director is responsible for its daily administration. The Authority administers approximately 2,909 Section 8 housing choice vouchers. The housing assistance payments for the month of August 2005 totaled more than $1.7 million. Our audit objectives were to determine whether Section 8 units met housing quality standards and whether tenant subsidies were limited to the amount allowed for the unit size authorized by the families’ composition. Table of Contents 5 RESULTS OF AUDIT Finding 1: The Authority Paid Section 8 Subsidies for Some Units That Did Not Meet Housing Quality Standards We inspected 67 units and determined that 20 did not meet housing quality standards. Of the 20 units, 8 were in material noncompliance. As a result, the tenants lived in units that had one or more material violations. This condition primarily occurred because the Authority’s inspectors did not identify violations that existed at the time of inspection or identified the conditions but did not report the units as being in noncompliance. The Authority paid $31,474 in ineligible housing assistance payments for the 8 units with material violations. The 8 units represent 11.94 percent of the 67 units inspected. Based on this percentage, we estimate the Authority will pay more than $1.14 million for units with material violations. Units Had Material Housing Quality Standards Violations We inspected 67 units with a HUD public housing inspector. The Authority’s lead inspector accompanied us on 40 of the inspections. The 8 units with one or more material violations involved conditions that the Authority either did not report or noted but did not report as noncompliance when it last inspected the units. We provided the Authority with a copy of our inspection report for each of the 20 failed units for consideration and initiation of corrective action. The following table summarizes the deficiencies for the 8 units with material violations. Type of material violations Sample Violations item Electrical Vermin not Total number hazards Structural Appliance infestation classified as deficiencies s material 14 2 1* 1* 1 1 6 27 1 2* 1 4 62 1* 1 1 3 83 2* 1 3 47 1 1* 1 3 12 1* 1* 2 13 1* 1 2 25 1* 1 Total 10 7 1 1 5 24 * This category includes one or more violations that existed when the Authority inspected the unit. Table of Contents 6 We determined the eight units with material violations by assessing factors such as (a) deficiencies that had existed for an extended period, (b) deficiencies noted in prior inspections but not corrected, and (c) deferred maintenance. We determined that eight tenants lived in units that had one or more material violations. The remaining 12 units involved violations that required corrective action, but we did not determine them to be material violations primarily because they occurred after the Authority’s last inspection. Electrical Hazards Were the Most Prominent Violations Electrical hazards were the most prominent violations detected during our inspections. Each of the eight units had one or more electrical hazards. The hazards included conditions such as exposed wiring and inoperable smoke detectors. For instance, we found exposed wiring in some units where children resided, including one house with exposed wiring at the light switch and breaker box in the utility/laundry room. Exposed breaker box wires Exposed light switch wire The above conditions existed at the time of the Authority’s most recent unit inspection, but the inspector did not identify and report the violations. Structural Violations Were Identified We identified one or more structural violations at six of the eight units that failed with material noncompliance. For instance, we identified one unit with cracked carport ceiling support beams and another unit with damaged doors. Table of Contents 7 First cracked carport beam Second cracked carport beam Damaged exterior door The Authority identified the two cracked carport support beams during its inspection but passed the unit. The cracked beams could result in roof collapse. In the other instance, the Authority did not identify the damaged door. The door was not airtight and allowed air and/or moisture to enter the unit. Federal regulations at 24 CFR [Code of Federal Regulations] 982.401(a)(3) state that all program housing must meet housing quality standards performance requirements, both at commencement of assisted occupancy and throughout the assisted tenancy. Table of Contents 8 The Authority Needs to Ensure That Inspectors Identify and Report All Housing Quality Violations The Authority should improve controls to ensure that its inspectors identify and report all housing quality standards violations. The Authority’s inspection procedures appeared adequate, and if the inspectors had fully followed those procedures, they should have identified and reported the material violations for the eight units discussed above. We attribute the missed violations to the inspectors’ failure to properly review, consider, and report all housing quality standards violations for the units they inspected. None of the 67 inspected units appeared to be dilapidated, although eight units had one or more material violations. The Authority’s inspectors properly identified and reported the condition of 59, or 88 percent, of the 67 units we inspected. The Authority Has Begun to Take Corrective Actions The Authority requested the landlords and tenants to correct the deficiencies we reported for the 20 failed units. The Authority’s records for the eight units with material violations show that (a) four landlords completed the requested corrective action, (b) three landlords were provided abatement notices due to their failure to complete the requested repairs, and (c) one tenant moved before the Authority could determine whether the landlords completed the requested repairs. Conclusion The Authority paid $31,474 in ineligible housing assistance payments for the eight units with material violations. The eight units represent 11.94 percent of the 67 units inspected. Based on this inspection result, we estimate the Authority will pay more than $1.14 million for units with material violations in addition to the ineligible amount. As a result, some tenants lived in units that were not decent, safe, and sanitary, and the Authority made ineligible housing assistance payments that could have been used to assist other eligible tenants. Table of Contents 9 Recommendations We recommend that the director of the Office of Public Housing require the Authority to 1A. Abate Section 8 subsidies or terminate the HAP contracts on all units that do not meet standards if the violations detected by our inspection are not corrected in a timely manner. 1B. Develop and implement improved controls to ensure that each inspector properly reviews, considers, and reports all housing quality standards violations for the units inspected and to prevent more than $1.14 million from being spent on units that are in material noncompliance with standards. 1C. Repay $31,474 to its Section 8 program from nonfederal funds for housing assistance payments made for the eight units with material violations. Table of Contents 10 Finding 2: The Authority Paid Excess Subsidies for Five Overhoused Tenants The Authority generally issued the proper Section 8 voucher size to its tenants. However, it issued vouchers for 36 tenants for units larger than justified by their family composition (overhoused). As a result, the Authority paid $10,393 in ineligible costs for excessive subsidies paid on behalf of five tenants and increased the potential for excessive subsidy payments for an additional 31 overhoused tenants. These conditions occurred because the Authority did not consistently comply with requirements designed to prevent the issuance of Section 8 vouchers for units larger than justified by a family’s composition and the associated risk of excessive subsidy payments. Improper Voucher Size Results in Excessive Subsidy Payments We conducted a computer assessment of the Authority’s 2,909 Section 8 vouchers and identified 53 tenants who appeared to be overhoused. We reviewed the files for 22 tenants and determined that the Authority paid $10,393 in excessive subsidies on behalf of 5 of the 22 tenants. In two cases, the Authority issued the wrong voucher size from the beginning of the tenants’ participation in the Section 8 program and did not detect the error. In the other three cases, the Authority failed to downsize the voucher at the next annual recertification to reflect reported changes in the families’ composition. As a result, the Authority continued to pay subsidies based on an incorrect payment standard and/or utility allowance for units larger than justified by the families’ composition. Our computer assessment of the remaining 31 units showed potential for excessive subsidy payments because the tenants were issued or retained larger vouchers than appeared justified by their family composition. However, the Authority did not make excessive subsidy payments on behalf of these tenants because their low unit rent resulted in subsidies that were less than the amounts authorized for the correct unit size. Federal regulations at 24 CFR [Code of Federal Regulations] 982.402(b)(1) provide that when determining unit size, the subsidy standards must provide for the smallest number of bedrooms needed to house a family without overcrowding. The regulations at 24 CFR 982.402 (c) provide that the payment standard for a family shall be the lower of (a) the payment standard amount for the family unit size or (b) the payment standard amount for the unit size of the unit rented by the family. Table of Contents 11 The Authority did not consistently comply with requirements designed to prevent the issuance of Section 8 vouchers for units larger than justified by a family’s composition and the associated risk of excessive subsidy payments. This noncompliance includes the Authority’s failure to initially determine the correct voucher size and to adjust tenant vouchers in a timely manner to reflect reported changes in family composition. The $10,393 paid for excessive subsidies reduced Section 8 assistance available through the Authority for other families to obtain decent, safe, and sanitary housing. Recommendations We recommend that the director of the Office of Public Housing require the Authority to 2A. Reimburse its Section 8 program $10,393 for excess housing assistance payments from nonfederal funds plus any additional amount up to the point that corrective action is completed. 2B. Develop controls to ensure initial determination of the correct voucher size and to adjust tenant vouchers in a timely manner to reflect reported changes in family composition. 2C. Adjust, where applicable, the vouchers for the 36 tenants to reflect the correct voucher size authorized by the families’ composition. Table of Contents 12 SCOPE AND METHODOLOGY To accomplish our audit objective, we • Reviewed applicable laws, regulations, and other HUD program requirements. • Reviewed the Authority’s Section 8 policies and procedures and administrative plan. • Interviewed Jacksonville, Florida, Office of Public Housing program officials and the Authority’s management and staff. • Reviewed the Authority’s fiscal year 2004 independent public accountant report and HUD program monitoring reviews. • Obtained a download of the Authority’s Section 8 housing stock for the Housing Choice Voucher program as of August 31, 2005. We then tested the reliability and validity of the data. Based on the tests, we assessed the data as sufficiently reliable, given our objective and intended use. • Assessed the files for 22 of 53 tenants identified through computer analysis as possibly housed in units larger than justified by their family composition. We recalculated the housing assistance to determine whether this condition resulted in excessive subsidy payments. When making the calculations, we relied on the income and deductions documented in the Authority’s files. We did not reverify or confirm the accuracy of the income and deductions. We obtained a listing of the Authority’s current units from the housing assistance payment register as of August 31, 2005. We adjusted the listing to exclude units not located in the Orlando area, such as portable units for tenants with housing choice vouchers issued by the Orlando Housing Authority but who now live in the jurisdiction of other housing authorities. The Authority had 2,909 tenants as of August 31, 2005. We used a statistical software program to select a random sample from the 2,909 tenants. The software returned a sample size of 67 units with a random start based on a 90 percent confidence level, 10 percent precision level, and 50 percent expected error rate. We selected an additional 67 units to be used for replacements if needed. We inspected 67 units with a HUD inspector from the Jacksonville, Florida, Office of Public Housing to determine whether the units met housing quality standards. The Authority’s lead inspector accompanied us on 40 inspections. We performed the inspections between October 31 and December 20, 2005. We selected 16 of the replacement units (68 through 83) because 12 units were vacant by the time of our inspection, two units were no longer being subsidized, and two tenants were not home. We identified the eight units with material violations after giving consideration to factors such as (a) deficiencies that had existed for an extended period of time, (b) deficiencies noted in a prior 13 Table of Contents inspection but not corrected, and/or (c) deferred maintenance that consistently fails the unit. We further based our assessment on prior Authority inspection reports, tenant comments, and our observation and judgment based on our unit inspections. Projecting the results of the eight failed units with material violations in our statistical sample to the population indicates • The lower limit is 5.50 percent x 2,909 units = 159 units not meeting housing quality standards. • The point estimate is 11.94 percent x 2,909 units = 348 units not meeting housing quality standards. • The upper limit is 18.38 percent x 2,909 units = 534 units not meeting housing quality standards. The Authority’s August 31, 2005, housing assistance payments documentation showed that the average monthly housing assistance payment was $601. Using the lower limit of the estimate of the number of units and the average monthly housing assistance payment, we estimated that the Authority will annually spend at least $1,146,708 (159 units x $601 average payment x 12 months) for units that are in material noncompliance with housing quality standards. This estimate is presented solely to demonstrate the annual amount of Section 8 funds that could be put to better use on decent, safe and sanitary housing if the Authority implements our recommendation. While these benefits would recur indefinitely, we were conservative in our approach and only included the initial year in our estimate. We also considered that (1) the Authority did not identify many of the past conditions during its most recent inspections, (2) the units would not be scheduled for another inspection for another year under normal circumstances, and (3) it would take the Authority at least a year to complete all inspections under an improved inspection process. We calculated $31,474 in ineligible subsidies for the units in material noncompliance by considering among other factors, the length of time the deficiencies existed and a 30-day period for responsible parties to correct the deficiencies. The audit generally covered the period of April 1, 2003, through August 31, 2005. We extended the period as needed to accomplish our objectives. We conducted our fieldwork from October through December 2005 at HUD, the Authority, and the homes of various tenants located within the Authority’s jurisdiction. We conducted the audit in accordance with generally accepted government auditing standards. Table of Contents 14 INTERNAL CONTROLS Internal control is an integral component of an organization’s management that provides reasonable assurance that the following objectives are being achieved: • Effectiveness and efficiency of operations, • Reliability of financial reporting, and • Compliance with applicable laws and regulations. Internal controls relate to management’s plans, methods, and procedures used to meet its missions, goals, and objectives. Internal controls include the processes and procedures for planning, organizing, directing, and controlling program operations. They include the systems for measuring, reporting, and monitoring program performance. Relevant Internal Controls We determined the following internal controls were relevant to our audit objectives: • Controls over program operations, • Controls over the validity and reliability of data, • Controls over compliance with laws and regulations, and • Controls over the safeguarding of resources. We assessed the relevant controls identified above. A significant weakness exists if management controls do not provide reasonable assurance that the process for planning, organizing, directing, and controlling program operations will meet the organization’s objectives. Significant Weaknesses Based on our review, we believe that the following item is a significant weakness: • The Authority needs to improve controls to ensure that its inspectors properly review, consider, and report all housing quality standards violations for the units they inspect (finding 1). Table of Contents 15 APPENDIXES Appendix A SCHEDULE OF QUESTIONED COSTS AND FUNDS TO BE PUT TO BETTER USE Funds to be put Recommendation Ineligible 1/ to better use 2/ 1B $1,146,708 1C $31,474 2A $10,393 ________ Total $41,867 $1,146,708 1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity that the auditor believes are not allowable by law; contract; or federal, state, or local policies or regulations. 2/ “Funds to be put to better use” are estimates of amounts that could be used more efficiently if an Office of Inspector General (OIG) recommendation is implemented. This includes reductions in outlays, deobligation of funds, withdrawal of interest subsidy costs, costs not incurred by implementing recommended improvements, avoidance of unnecessary expenditures noted in preaward reviews, and any other savings which are specifically identified. In this instance, if the Agency implements our recommendation, it will cease to incur Section 8 costs for units that are not “decent, safe and sanitary,” and, instead will expend those funds for units that meet HUD’s standards. Once the Agency successfully improves its controls, this will be a recurring benefit. Our estimate reflects only the initial year of these recurring benefits. Table of Contents 16 Appendix B AUDITEE COMMENTS AND OIG’S EVALUATION Ref to OIG Evaluation Auditee Comments Comment 1 Comment 2 Table of Contents 17 Comment 3 Table of Contents 18 Comment 1 Table of Contents 19 OIG Evaluation of Auditee Comments Comment 4 Comment 5 Comment 5 Comment 2 Table of Contents 20 Comment 6 Comment 2 Comment 6 Comment 4 Comment 7 Comment 4 Comment 8 Table of Contents 21 Comment 4 Comment 9 Comment 4 Comment 10 Table of Contents 22 Comment 4 Comment 11 Comment 4 Comment 12 Comment 4 Comment 13 Table of Contents 23 Comment 4 Comment 14 Comment 4 Comment 15 Table of Contents 24 Comment 4 Comment 2 Table of Contents 25 Comment 3 Comment 1 Comment 6 Table of Contents 26 Table of Contents 27 Table of Contents 28 Comment 16 Table of Contents 29 Table of Contents 30 Comment 16 Table of Contents 31 Table of Contents 32 Comment 17 Table of Contents 33 Table of Contents 34 Table of Contents 35 Comment 16 Table of Contents 36 Table of Contents 37 Comment 16 Table of Contents 38 Table of Contents 39 Comment 18 Table of Contents 40 Table of Contents 41 Comment 18 Table of Contents 42 Table of Contents 43 Comment 18 Table of Contents 44 Table of Contents 45 Comment 19 Table of Contents 46 Table of Contents 47 OIG Evaluation of Auditee Comments Comment 1 The Authority commented that our report did not acknowledge the hurricanes that occurred and the impact they caused. We recognize the hurricane’s general impact as noted in the Authority’s written response. However, the audit objectives addressed the Authority’s housing quality standard inspections and whether the Authority issued the correct voucher size to section 8 tenants. The Authority provided no support that hurricane related issues substantially hampered its recent ability to perform duties specifically related to the audit objectives. Comment 2 The Authority commented that our protocol was fundamentally flawed and led to unsupportable conclusions. They also commented that too much time elapsed between their inspection and our audit (four to eleven months) and the conditions noted by the OIG were from normal wear and tear and/or tenant caused damage versus by an error or omission of the OHA’s inspections. We planned and conducted the audit according to generally accepted government auditing standards. We requested the Authority’s written response and adjusted the report where appropriate. For instance, see comments 3, 4, 14, and 16 below. The adjustments did not materially change our conclusions. We disagree with the Authority’s blanket assertion that we reached unsupported conclusions. The conditions noted by the OIG, which were attributed to OHA inspections, are valid. Our methodology included interviewing tenants and owners to supplement our physical observations concerning the violations and how long they existed. Comment 3 We reassessed and concur with the Authority’s position that for overhoused tenants the new family unit size must be used to determine the payment standard amount beginning at the family’s first regular re-examination following the change in the family size. We revised the report accordingly. Comment 4 The Authority disagreed with our comment that the “condition primarily occurred because the Authority’s inspectors did not identify violations that existed at the time of inspection or identified the conditions but did not report the units as being in noncompliance.” We clarified the report to identify the units with one or more material violations that existed at the time of the Authority’s inspection. Our conclusions were based on observations we made during the unit inspections, interviews with the tenants, interviews with the owners, and review of the Authority’s files. The Authority cited disagreement based on their consideration of similar information. We maintain the position cited in the report. Comment 5 The Authority provided no support for its claim that, “The Section 8 Participants’ signed statements in the inspection files document that the conditions identified by the OIG did not exist at the time of the OHA inspection”. The Authority comment was made in reference to the tenants response to two questions asked by Table of Contents 48 the inspector and recorded on Inspection Form HUD-52580, page 19, section D. The questions asked, (a) does the owner make repairs when asked, and (b) is there anything else you want to tell us? The absence of a tenant complaint against the owner or the tenant voicing other concerns to the inspector does not support the Authority’s claim that the tenants’ signed statement documents that the OIG claimed conditions did not exist. We maintain the accuracy of our conclusion based on our inspection results and discussions with the tenants and with the owners. Comment 6 The Authority commented that between the times they inspected the units and our audit, three category 3 devastating hurricanes occurred (Charley, Frances, and Jeanne). The Authority’s claim is not correct. Hurricanes Charlie, Frances, and Jeanne occurred between August and September 2004. The Authority conducted its inspections between December 2004 and October 2005. Our audit began in August 2005 and we conducted our inspections from October 31 to December 20, 2005. Comment 7 Sample item number 14 - The Authority’s inspection report showed that one burner was not working on the stove. The violation should have caused the unit to fail, but the Authority’s inspector passed the unit. By the time we inspected the unit two burners were not working. At the exit conference, Authority officials agreed that their inspector should have failed this unit. Comment 8 Sample item number 27 - The Authority questioned the accuracy of the owner’s statement regarding the date she purchased the unit and the conditions we noted during the inspection. We had no reason to doubt what the owner told us. The results of our inspections were valid. The Authority communicated our inspection results to the owner and obtained corrective action. Comment 9 Sample item number 62 - Based on an assessment of the Authority’s response we revised the report to omit one of the two reported electrical violations. The Authority communicated the results of our inspection to the owner and obtained corrective action. Comment 10 Sample item number 83 - The Authority’s comments seek to dismiss the validity of our inspection results based on the absence of a tenant complaint involving the conditions detected during our inspection. We do not know why the Authority’s files did not contain a copy of the complaint letter we obtained from the tenant. The results of our inspection are valid. The Authority communicated our inspection results to the owner followed by a notice of abatement because their reinspection showed the owner did not repair the conditions noted in our inspection report. Comment 11 Sample item number 47 - The Authority’s comment indicates the tenant comments to them matched what the tenant told us. However, the Authority dismissed the validity of the tenant’s comments based on the absence of a tenant 49 Table of Contents complaint. The results of our inspection are valid. The Authority communicated our inspection results to the owner followed by a notice of abatement because their reinspection showed the owner did not repair the condition noted in our inspection report. Comment 12 Sample item number 12 - The Authority’s comments provided no information that warranted a revision to our conclusion. The results of our inspection are valid. The Authority communicated the results of our inspection to the owner and obtained corrective action. Comment 13 Sample item number 13 - The Authority questioned the accuracy of what the tenant told us when we inspected the unit. We had no reason to doubt what the tenant told us. The results of our inspection are valid. The Authority communicated our inspection results to the owner and obtained corrective action. Comment 14 Sample item number 67 – We deleted this unit from the report based on consideration of the Authority’s comments and their reinspection of the unit. Comment 15 Sample item number 25 - The Authority’s comments acknowledged uncertainty about whether its inspector carefully examined the unit for the item detected by our inspection. The Authority stated that it would provide additional training to its inspectors concerning this type electrical condition. Comment 16 We assessed and agree with the Authority’s written comments for clients 4561, 4137, 1070 and 3878. We revised finding 2 to remove reference to the four tenants. Comment 17 Clients 5980 - The Authority comment indicates they did not adjust the tenants voucher size because the change in family composition was not reported until 3/5/04. The Authority’s comments show the annual recertification process started on 1/1/04 with an effective completion date of 4/1/04. The Authority provided documents that show the actual change in composition occurred in February 2004. The Regulations, 24 CFR 982.505c(5) require adjustment to the unit size beginning at the family’s first regular reexamination following the change in family unit size. Therefore, the position cited in the finding is consistent with the regulations that required the adjustment effective with the 4/1/04 annual reexamination. Comment 18 Clients 25529, 27196, and 31308 - The Authority commented that due to the recent hurricanes they allowed the tenants to remain in the units they occupied rather than have households seeking new housing. The tenant file we examined did not document the reason cited in the Authority’s written comment for not making the changes. We did not revise the report because the basis for the adjustments are regulatory (24 CFR 982.505c(5)). Table of Contents 50 Comment 19 Client 36608 - The Authority indicated that the client ported in from another PHA with a 3-bedroom voucher for two disabled people. It also indicated that both family members are disabled and a medical letter in the file triggered reasonable accommodation. We reviewed the tenant file and determined that it contained a handwritten note from the initial PHA requesting the Authority issue a 3-bedroom voucher due to the clients’ disabilities. The handwritten note was not an adequate substitute for the required medical documentation. The Authority’s written comment states, “At the reexam 07/01/06, the client will be issued a voucher that is appropriate for their family size. The Authority’s comment provided no information that justified a revision to the position cited in the finding. Table of Contents 51
The Orlando Housing Authority Did Not Ensure That All Section 8 Units Met Housing Quality Standards and Paid Excessive Subsidies for Some Units
Published by the Department of Housing and Urban Development, Office of Inspector General on 2006-05-31.
Below is a raw (and likely hideous) rendition of the original report. (PDF)