HVC Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). (3) Determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (6) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516).HVC Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). (3) Determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (6) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Condition: Out of 40 tenant files tested for eligibility, 11 tenant files contained errors or were missing required documentation. Questioned costs: $25,596 Context: During the testing of 40 tenant files for eligibility, the following exceptions were noted: - 4 instances where there was not any income support in the tenant file or the income listed on the HUD-50058 was different than the income documentation in the tenant file - 5 instances where the HAP calculation was incorrectly calculated due to incorrect inputs on the HUD-50058 - 5 instances where the recertification of the HUD-50058 was not performed annually - 1 instance where the Authority was unable to locate the HUD-9886 general release form Cause: The Authority failed to implement the internal controls designed to ensure compliance with eligibility requirements were met. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements determined by HUD. Errors in eligibility could result in incorrect HAP payments. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend the Authority: - Review and revise its eligibility determination procedures to ensure full compliance with HUD regulations. - Train staff on proper documentation and verification protocols for income, citizenship/immigration status, Social Security numbers, and student eligibility. - Conduct a file audit to identify and correct any improperly admitted tenants. - Update its Administrative Plan to reflect accurate eligibility screening procedures. Views of responsible officials: There is no disagreement with the audit finding.
HVC PIC Submissions Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an issuance, admission, annual reexamination, interim reexamination, portability move-in, expiration, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: Out of 40 HUD-50058’s tested for PIC submissions, 14 HUD-50058 PIC uploads contained errors or were not uploaded timely. Questioned costs: None Context: During the testing of 40 tenant files for PIC submissions, the following exceptions were noted: - 1 instance where the HUD-50058 PIC upload could not be located - 2 instances where the HAP amount on the HUD-50058 in PIC did not match the HAP amount of HUD-50058 tested in the tenant file - 14 instances where the HUD-50058 was not uploaded into PIC within 90 days of the effective date. Cause: The Authority failed to implement internal controls designed to ensure accurate HUD-50058 information is submitted into the PIC system within 90 days of effective date. Effect: The Authority is not in compliance with federal regulations regarding PIC submission requirements determined by HUD. Repeat Finding: No Recommendation: We recommend the Authority to designate an individual to ensure accurate HUD-50058 information is inputted into the PIC system timely. Views of responsible officials: There is no disagreement with the audit finding.
HVC Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The 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 10 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) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: Out of 25 tenant files tested for rent reasonableness, 2 tenant files contained exceptions. Questioned costs: $4,416 Context: During the testing of 25 tenant files for rent reasonableness, there were 2 instances where the contract rent per the HUD-50058 was greater than the approved rent per the rent determination form. Cause: The Authority failed to implement internal controls designed to ensure the proper reasonable rent is used on the HUD-50058. Effect: The Authority is not in compliance with federal regulations regarding reasonable rent requirements determined by HUD. Repeat Finding: No Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
HVC HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: NE 001; 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: Out of 40 tenant files tested for annual HQS inspections, 6 tenant files contained exceptions. Questioned costs: None Context: During the testing of 40 tenant files for annual HQS inspections, there were 6 instances where the unit was not inspected on an annual basis Cause: The Authority failed to implement internal controls designed to ensure the units are inspected annually. Effect: The Authority is not in compliance with federal regulations regarding HQS inspection requirements determined by HUD. Repeat Finding: No Recommendation: We recommend the Authority implement controls to ensure that all units are inspected annually. We recommend the Authority hire an outside firm to perform inspections if there is not capacity internally. Views of responsible officials: There is no disagreement with the audit finding.