Criteria: In accordance with 24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507, the public housing agency (PHA) must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)
Condition: The Authority was unable to provide records to document the basis for the determination that rent to owner is reasonable for two out of forty participant households tested.
Questioned Costs: None.
Cause and Effect: The cause is the lack of file reviews for new staff hires. The effect is inappropriate rent subsidy could be applied.
Recommendation: We recommended the Authority have a reviewer perform a tenant file review once a staff member completes a tenant’s file.
Management’s Response: The Authority has implemented the following in response to this finding:
• All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application.
• Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy.
• SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.
Criteria: In accordance with 24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507, the public housing agency (PHA) must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)
Condition: The Authority was unable to provide records to document the basis for the determination that rent to owner is reasonable for two out of forty participant households tested.
Questioned Costs: None.
Cause and Effect: The cause is the lack of file reviews for new staff hires. The effect is inappropriate rent subsidy could be applied.
Recommendation: We recommended the Authority have a reviewer perform a tenant file review once a staff member completes a tenant’s file.
Management’s Response: The Authority has implemented the following in response to this finding:
• All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application.
• Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy.
• SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.
Criteria: In accordance with 24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507, the public housing agency (PHA) must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)
Condition: The Authority was unable to provide records to document the basis for the determination that rent to owner is reasonable for two out of forty participant households tested.
Questioned Costs: None.
Cause and Effect: The cause is the lack of file reviews for new staff hires. The effect is inappropriate rent subsidy could be applied.
Recommendation: We recommended the Authority have a reviewer perform a tenant file review once a staff member completes a tenant’s file.
Management’s Response: The Authority has implemented the following in response to this finding:
• All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application.
• Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy.
• SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.
Criteria: In accordance with 24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507, the public housing agency (PHA) must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)
Condition: The Authority was unable to provide records to document the basis for the determination that rent to owner is reasonable for two out of forty participant households tested.
Questioned Costs: None.
Cause and Effect: The cause is the lack of file reviews for new staff hires. The effect is inappropriate rent subsidy could be applied.
Recommendation: We recommended the Authority have a reviewer perform a tenant file review once a staff member completes a tenant’s file.
Management’s Response: The Authority has implemented the following in response to this finding:
• All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application.
• Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy.
• SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.
Criteria: In accordance with 24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507, the public housing agency (PHA) must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)
Condition: The Authority was unable to provide records to document the basis for the determination that rent to owner is reasonable for two out of forty participant households tested.
Questioned Costs: None.
Cause and Effect: The cause is the lack of file reviews for new staff hires. The effect is inappropriate rent subsidy could be applied.
Recommendation: We recommended the Authority have a reviewer perform a tenant file review once a staff member completes a tenant’s file.
Management’s Response: The Authority has implemented the following in response to this finding:
• All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application.
• Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy.
• SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.
Criteria: In accordance with 24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507, the public housing agency (PHA) must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)
Condition: The Authority was unable to provide records to document the basis for the determination that rent to owner is reasonable for two out of forty participant households tested.
Questioned Costs: None.
Cause and Effect: The cause is the lack of file reviews for new staff hires. The effect is inappropriate rent subsidy could be applied.
Recommendation: We recommended the Authority have a reviewer perform a tenant file review once a staff member completes a tenant’s file.
Management’s Response: The Authority has implemented the following in response to this finding:
• All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application.
• Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy.
• SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.