2025-001: Non-Compliance with Waiting List Requirements Condition: Housing Voucher Cluster waiting list is not being maintained in accordance with federal requirements or its own Administrative Plan. Applicant names were not removed when required, and updates to applicant information were not consistently recorded or verified. Criteria: Per 24 CFR 982.54(d)(1), the Public Housing Agency (PHA) Administrative Plan must include policies for managing the Housing Choice Voucher (HCV) waiting list, including the method for organizing, applying selection preferences, maintaining the list, and updating applicant information. Additionally, 24 CFR 982.204(a) requires the PHA to select applicants from the waiting list in accordance with the PHA’s written policies and applicable regulatory requirements. PHA policy further requires periodic updating of the waiting list, removal of applicants who fail to respond to update notices, and proper documentation of all additions, removals, and changes. Cause: The PHA did not maintain the waiting list in accordance with federal requirements or its own Administrative Plan. Applicant names were not removed when required, and updates to applicant information were not consistently recorded or verified. These deficiencies indicate that internal controls over the waiting list process were not operating effectively, and staff did not adhere to established procedures. Effect: Because the waiting list was not adequately updated and applicant names were not removed as required, auditors could not determine whether applicants were selected for admission in the correct order or in compliance with federal regulations and PHA policy. This increases the risk of improper or inequitable admissions decisions, inaccurate reporting, potential Fair Housing implications, and an inability to substantiate compliance with mandatory procedures. Recommendation: The PHA should strengthen internal controls over waiting list management. Actions should include: 1. Updating the waiting list to ensure all information, removals, and changes are accurately documented. 2. Implementing or reinforcing procedures to ensure timely removal of applicants who fail to respond to update notices or are no longer eligible. 3. Providing staff training on federal requirements and PHA policy. 4. Establishing periodic monitoring to verify compliance and documentation accuracy.
2025-002: Record Keeping of Housing Voucher Cluster Tenant Files Condition: Housing Voucher Cluster tenant files are not being completed based on compliance requirements of HUD. Criteria: Housing Voucher Cluster tenant files should be maintained to ensure all compliance requirements of HUD are completed timely and appropriately. Cause: Housing Voucher Cluster tenant files are not being maintained with complete and accurate information. Information such as applications for admission or continued occupancy, HUD-9886 Authorization for the Release of Information/Privacy Act Notice, and support for rent calculations were either not filled out appropriately or were missing from the Housing Voucher Cluster tenant files. Effect: Noncompliance with requirements imposes a risk of penalties and fines assessed by HUD. Recommendation: Controls over record keeping and maintaining Housing Voucher Cluster tenant files should be strengthened with an increased emphasis on timely and appropriate documentation concerning all compliance requirements of HUD.
2025-003: NSPIRE/Housing Quality Standards Inspections Condition: Quality control re-inspections on units leased to families were not conducted at least biennially (within a two-year period) on 3 of 43 Housing Voucher Cluster tenants tested. Criteria: Public Housing Authorities must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards and the Public Housing Authority must conduct quality control re-inspections. Cause: Quality control re-inspections on units leased to families were performed outside of the two-year period on 3 of 43 Housing Voucher Cluster tenants tested. Effect: Noncompliance with requirements imposes a risk of penalties and fines assessed by HUD. Recommendation: Controls over Housing Quality Standards should be strengthened with an increased emphasis on timely re-inspections.
2025-004: Record Keeping of Reasonable Rent Documentation in Tenant File Condition: During testing of rent reasonableness documentation for tenants participating in the Housing Choice Voucher program, the PHA did not maintain a required rent reasonableness calculation worksheet for 1 of 43 tenant files selected for the fiscal year 2025. The tenant file lacked evidence showing how the PHA determined that the rent charged was reasonable compared to unassisted, comparable units in the market area. Criteria: The PHA Administrative Plan must state the method used to determine rent reasonableness, and this method must consider the unit’s location, quality, size, unit type, unit age, and any amenities, housing services, maintenance, and utilities provided by the owner. Rent reasonableness must be determined at initial leasing, before any rent increase, and 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 that document the basis for each rent reasonableness determination (initially and during the term of the HAP contract) per 24 CFR §§ 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507. Cause: 1 of the 43 Housing Voucher Cluster tenant files tested lacked properly maintained documentation to demonstrate that the required rent reasonableness worksheet and supporting comparability analysis were completed and retained as required. Effect: Without proper rent reasonableness documentation, the PHA cannot demonstrate that the rent charged for the assisted unit met federal requirements. Failure to maintain complete documentation increases the risk of noncompliance with HUD regulations, may result in improper use of federal funds, and could expose the PHA to future questioned costs or program sanctions if deficiencies persist. Recommendation: The PHA should strengthen internal controls over record keeping of reasonable rent documentation. Actions should include: 1. Implementing a standardized checklist that requires completion and retention of rent reasonableness documentation before file approval. 2. Update and reinforce staff training on rent reasonableness requirements under 24 CFR §§ 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507, ensuring all staff understand documentation and timing requirements. 3. Conduct periodic quality control reviews of tenant files to verify compliance with federal documentation standards and the PHA’s Administrative Plan.
2025-005: Housing Quality Standards (HQS) Enforcement Condition: 2 of 6 of tenants tested that had failed inspections did not have documentation in their tenant file to support that HQS deficiencies identified in units under a Housing Assistance Payments (HAP) contract were addressed within the required. Criteria: Under 24 CFR § 982.405(d), PHAs must ensure HQS deficiencies in HAP-assisted units are corrected within required timeframes. For life-threatening deficiencies, the PHA must inspect and notify the owner within 24 hours, and the owner must make repairs within 24 hours of notification. For non-life-threatening deficiencies, the PHA must inspect and notify the owner within 15 days, and the owner must correct the deficiency within 30 days or within an approved extension. If an owner fails to correct deficiencies within the required period, the PHA must abate HAP no later than the first of the month following the correction deadline or terminate the HAP contract. Owners are not responsible for deficiencies caused by the family, including failure to pay required utilities or tenant-caused damage. Under 24 CFR §§ 982.158(d) and 982.404, for family-caused deficiencies that are not corrected, the PHA must take prompt enforcement action against the family. Cause: Housing Voucher Cluster tenant files are not being maintained with complete and accurate information. Information such as documentation to support that HQS deficiencies identified in units under a HAP contract were addressed within the required timeframes were missing from the Housing Voucher Cluster tenant files. Effect: Failure to maintain documentation demonstrating that HQS deficiencies were corrected within required timeframes increases the risk that assisted units may continue to operate with unresolved health and safety issues. Without adequate records, the PHA cannot demonstrate compliance with federal requirements governing the Housing Choice Voucher program. This may result in participants residing in units that do not meet HUD’s minimum housing quality standards, potential exposure to HUD monitoring findings, and the risk of repayment or other administrative sanctions. Recommendation: We recommend that the PHA strengthen its internal controls and file management procedures to ensure that all documentation related to HQS deficiencies—including inspection reports, owner notifications, repair verification, and any HAP abatement actions—is consistently maintained in tenant files. The PHA should: 1. Implement a standardized checklist or documentation protocol for HQS deficiency follow-up. 2. Provide staff training on required HUD timelines and documentation standards. 3. Periodically review tenant files to ensure completeness and compliance.
2025-006: Housing Assistance Payments (HAP) Condition: During testing of HAP for tenants participating in the Housing Choice Voucher program, the PHA did not maintain a HAP contract and tenancy addendum for 6 of 43 tenant files selected for the fiscal year 2025. The tenant file lacked evidence showing that the PHA maintained these legal binding documents that signifies agreement of the contract terms from all parties. Criteria: Per 24 CFR section 982.158 and 24 CFR Part 982, Subpart K, the PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register. Cause: Housing Voucher Cluster tenant files are not being maintained with complete and accurate information. Information such as HAP contracts and tenancy addendums were missing from the Housing Voucher Cluster tenant files. Effect: Without complete HAP contracts and tenancy addendums, the PHA cannot demonstrate that assisted units were under valid and enforceable agreements as required by HUD regulations. Missing documentation increases the risk of improper HAP payments, weakens the PHA’s ability to enforce landlord and tenant obligations, and exposes the agency to potential HUD monitoring findings, repayment requirements, or other compliance actions. Recommendation: We recommend that the PHA strengthen controls over tenant file maintenance to ensure that fully executed HAP contracts and tenancy addendums are obtained, retained, and properly filed for all Housing Choice Voucher participants. The PHA should: 1. Implement a standardized file checklist to confirm required documents are present prior to approving HAP payments. 2. Provide staff training on documentation requirements under 24 CFR Part 982. 3. Periodically perform internal file reviews to verify that HAP contracts and tenancy addendums are consistently maintained.