Finding Text
2023-002 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027.
o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent.
• 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent:
o Food assistance was included as income when it should have been excluded.
o The tenant’s utility allowance was misreported on the 50058.
• 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183.
• 1 tenant fille error where the tenant did not sign the lease agreement.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.