2023-001: Eligibility, Special Tests and Provisions (Reasonable Rent, Housing Assistance Payment)
– Significant Deficiency in Internal Controls over Compliance over Maintenance of Tenant Files
ALN and Title: 14.871 Section 8 Housing Choice Vouchers
Federal Agency: U.S. Department of Housing and Urban Development
Award Year: 2023
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish
and maintain effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework”, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Title 24 US Code of Federal Regulations Part 982 Subpart K requires housing authorities operating a
Section 8 program to examine and re-examine tenant eligibility regularly, ensure that rent paid under
the Section 8 program meets the definition of “reasonable rent” as defined by HUD, and requires certain
documentation to be maintained related to tenant rent and Housing Assistance Payments.
Condition: The Authority does not have effective controls over this compliance requirement, which
resulted in the following during our review of tenant files:
For one of the 49 tenant files tested, the Application had not been signed by the applicant.
For one of the 49 tenant files tested, the file did not contain a copy of the Rent Reasonable
Valuation form.
For one of the 49 tenant files tested, the HAP contract was not signed off as reviewed by the
Housing Specialist.
Cause: The Authority did not have controls in place to help follow the appropriate procedures in
accordance with procedures to ensure compliance.
Effect: The Authority may unintentionally approve a tenant who is not eligible which could lead to
questioned costs and/or repayment of funds to the Grantor agency.
Questioned Costs: None noted. Auditors’ Recommendation: The Auditors recommend that the Authority strengthen its controls over
tenant file documentation to ensure proper signoffs, forms, and data entry are present.
Views of Responsible Officials: The Housing Authority does have controls in place, we have file
checklists to be followed by the staff, but unfortunately, staff errors do occur. These items have been
addressed with staff.
Estimated Completion Date: September 30, 2023 Responsible Party: Executive Director
2023-002: Eligibility, Special Reporting, Special Tests and Provisions (Utility Allowance Schedule,
Housing Assistance Payment) – Significant Deficiency in Internal Controls over Compliance over
Tenant Calculations
ALN and Title: 14.871 Section 8 Housing Choice Vouchers
Federal Agency: U.S. Department of Housing and Urban Development
Award Year: 2023
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish
and maintain effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework”, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 24 US Code of Federal Regulations Part 982.517(d) Use of utility allowance schedule, the PHA
must use the appropriate utility allowance for the lesser of the size of dwelling unit actually leased by
the family or the family unit size as determined under the PHA subsidy standards. In cases where the
unit size leased exceeds the family unit size as determined under the PHA subsidy standards as a result
of a reasonable accommodation, the PHA must use the appropriate utility allowance for the size of the
dwelling unit actually leased by the family.
Condition: The Authority does not have effective controls over this compliance requirement, which
caused one of the 49 tenant files tested to include a clerical error in the Utility Allowance calculation
inputted into the software by the Housing Specialist. This in turn lowered the HAP payment by $18 and
is listed in the Family Report inaccurately.
Cause: The Authority did not have controls in place to help follow the appropriate procedures in
accordance with procedures to ensure compliance.
Effect: The Authority may unintentionally approve a tenant for an incorrect amount of assistance which
could lead to questioned costs and/or repayment of funds to the Grantor agency and inaccurate
reporting.
Questioned Costs: $18 of known questioned costs and $2,685 of likely questioned costs when
extrapolated to the population. Auditors’ Recommendation: The Auditors recommend that the Authority strengthen its controls over tenant files and eligibility determinations to ensure that information is accurately transferred into the system used for eligibility determinations and assistance calculations. Views of Responsible Officials: : The Housing Authority does have controls in place, we require staff to
manually calculate the rent and utility allowance and then compare to the computer generated calculations, but unfortunately, staff errors do occur. These items have been addressed with staff and the HAP was recalculated with the correct utility allowance and the additional HAP was paid to the appropriate party in September.
Estimated Completion Date: September 30, 2023 Responsible Party: Executive Director
2023-001: Eligibility, Special Tests and Provisions (Reasonable Rent, Housing Assistance Payment)
– Significant Deficiency in Internal Controls over Compliance over Maintenance of Tenant Files
ALN and Title: 14.871 Section 8 Housing Choice Vouchers
Federal Agency: U.S. Department of Housing and Urban Development
Award Year: 2023
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish
and maintain effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework”, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Title 24 US Code of Federal Regulations Part 982 Subpart K requires housing authorities operating a
Section 8 program to examine and re-examine tenant eligibility regularly, ensure that rent paid under
the Section 8 program meets the definition of “reasonable rent” as defined by HUD, and requires certain
documentation to be maintained related to tenant rent and Housing Assistance Payments.
Condition: The Authority does not have effective controls over this compliance requirement, which
resulted in the following during our review of tenant files:
For one of the 49 tenant files tested, the Application had not been signed by the applicant.
For one of the 49 tenant files tested, the file did not contain a copy of the Rent Reasonable
Valuation form.
For one of the 49 tenant files tested, the HAP contract was not signed off as reviewed by the
Housing Specialist.
Cause: The Authority did not have controls in place to help follow the appropriate procedures in
accordance with procedures to ensure compliance.
Effect: The Authority may unintentionally approve a tenant who is not eligible which could lead to
questioned costs and/or repayment of funds to the Grantor agency.
Questioned Costs: None noted. Auditors’ Recommendation: The Auditors recommend that the Authority strengthen its controls over
tenant file documentation to ensure proper signoffs, forms, and data entry are present.
Views of Responsible Officials: The Housing Authority does have controls in place, we have file
checklists to be followed by the staff, but unfortunately, staff errors do occur. These items have been
addressed with staff.
Estimated Completion Date: September 30, 2023 Responsible Party: Executive Director
2023-002: Eligibility, Special Reporting, Special Tests and Provisions (Utility Allowance Schedule,
Housing Assistance Payment) – Significant Deficiency in Internal Controls over Compliance over
Tenant Calculations
ALN and Title: 14.871 Section 8 Housing Choice Vouchers
Federal Agency: U.S. Department of Housing and Urban Development
Award Year: 2023
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish
and maintain effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework”, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 24 US Code of Federal Regulations Part 982.517(d) Use of utility allowance schedule, the PHA
must use the appropriate utility allowance for the lesser of the size of dwelling unit actually leased by
the family or the family unit size as determined under the PHA subsidy standards. In cases where the
unit size leased exceeds the family unit size as determined under the PHA subsidy standards as a result
of a reasonable accommodation, the PHA must use the appropriate utility allowance for the size of the
dwelling unit actually leased by the family.
Condition: The Authority does not have effective controls over this compliance requirement, which
caused one of the 49 tenant files tested to include a clerical error in the Utility Allowance calculation
inputted into the software by the Housing Specialist. This in turn lowered the HAP payment by $18 and
is listed in the Family Report inaccurately.
Cause: The Authority did not have controls in place to help follow the appropriate procedures in
accordance with procedures to ensure compliance.
Effect: The Authority may unintentionally approve a tenant for an incorrect amount of assistance which
could lead to questioned costs and/or repayment of funds to the Grantor agency and inaccurate
reporting.
Questioned Costs: $18 of known questioned costs and $2,685 of likely questioned costs when
extrapolated to the population. Auditors’ Recommendation: The Auditors recommend that the Authority strengthen its controls over tenant files and eligibility determinations to ensure that information is accurately transferred into the system used for eligibility determinations and assistance calculations. Views of Responsible Officials: : The Housing Authority does have controls in place, we require staff to
manually calculate the rent and utility allowance and then compare to the computer generated calculations, but unfortunately, staff errors do occur. These items have been addressed with staff and the HAP was recalculated with the correct utility allowance and the additional HAP was paid to the appropriate party in September.
Estimated Completion Date: September 30, 2023 Responsible Party: Executive Director