We audited the Kentucky Commission on Human Rights’ fair housing complaint intake process.  We initiated this audit based on an internal risk assessment of Fair Housing Assistance Program agencies’ challenges.  Our audit objectives were to (1) determine the extent to which the Commission processed fair housing inquiries within 30 days and (2) evaluate its reasons for closing fair housing inquiries.

We were unable to determine the extent to which the Commission processed fair housing inquiries within 30 days due to a lack of supporting documentation.  Also, the Commission could not provide evidence that would have allowed us to determine whether fair housing inquiries were properly closed.  In addition, the Commission did not have clarity on what inquiries should be recorded in the U.S. Department of Housing and Urban Development’s (HUD) Enforcement Management System (HEMS) or what type of documents should be recorded in that system to support closure decisions.  These conditions occurred because the Commission lacked staffing for its housing intake process, lacked an effective system to track the processing of inquiries, and was not always able to retrieve documents because some emails were lost.  Also, the Commission did not have a record retention policy for its intake, and its staff was inadequately trained for recording intake data in HEMS.  As a result, the Commission could not consistently provide assurance to its customers that it properly processed and closed inquiries from complainants in a timely manner.  If complainants’ alleged discrimination is not addressed properly and in a timely manner, the Commission may not help to stop ongoing discrimination, hold those responsible for their actions, and deter future discrimination.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to (1) update its intake policy and procedure to clarify which inquiries are to be recorded in HEMS; (2) develop an internal agency intake training guide, distribute it to all agency housing staff members, and ensure that all intake staff members participate in HUD-approved training related to intake; (3) implement a record retention policy to ensure that decisions on inquiries are sufficiently supported; (4) implement a plan to ensure that it has sufficient staff to meet its obligations under the Fair Housing Assistance Program cooperative agreement; and (5) implement a system to better track the intake and processing of potential fair housing inquiries.