Finding Text
2024-001 ALN 14.195 – Section 8 Housing Assistance Payments Program – Eligibility
Condition and Criteria:
During our audit, it was determined that significant deficiencies in internal controls existed
over the Company’s Section 8 Housing Assistance Payments Program's eligibility process
being compliant with HUD regulatory requirements.
As a condition of admission to or continued assistance the Company must obtain a consent
form authorizing any depository or private source of income, or any Federal, State or local
agency, to furnish or release to the Company such information necessary. The Company
must then accurately determine income eligibility and calculate tenants' rent payments using
this documentation. In order to monitor compliance with income eligibility, the Company
must comply with HUD-prescribed reporting requirements that permit HUD to maintain the
data.
Amount of Questioned Costs:
None
Context: Out of the 12 tenant files tested, 10 instances were identified that indicated significant
deficiencies in internal controls. 5 of the files did not have the tenants complete a HUD
Form 9886 or 9887 within the past year, which is required as a condition of continued
occupancy. 3 of the tenant files did not have evidence that an EIV report was ran at least
annually to verify income reported by the tenants. 2 of the tenant files did not have adequate
documentation for income verification.
Cause:
The Company’s internal controls over the Section 8 Housing Assistance Payments Program's
eligibility determination process that were in place lacked the necessary controls over
information and communication of HUD regulatory requirements. The Company lacked an
understanding of HUD Section 8 Housing Assistance Program's eligibility requirements as
determined by 24 CFR.
Effect:
The Company potentially could be improperly performing annual and interim
reexaminations. This could cause some of the tenants to pay an incorrect rent amount in
accordance with HUD eligibility rules and regulations.
Auditor’s Recommendation:
We recommend that management implements the use of HUD form 9886 or 9887 and the
EIV reports during each annual recertification. We recommend that the staff continue to
obtain training through related training seminars and classes and to monitor HUD news and
notices for any new guidance or changes to the public housing industry. We also recommend
that a periodic review of the family income examinations and reexaminations be performed
to ensure that the Company is following HUD eligibility rules and regulations and, if any
errors have been made, that the Company can identify these quickly and take the necessary
corrective action.
Grantee Response:
Management acknowledges the finding and will follow the auditor’s recommendation.