Finding Text
Finding 2024-002 – Continuum of Care Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency
Continuum of Care Program - subsidy ALN #14.267
Condition & Cause:
We selected a sample of five (5) files for review. We noted the following errors of noncompliance:
• Two (2) files which contained delays in processing End of Participations (EoP)
• Three (3) files which did not contain evidence of an EIV in the file. Of these files two (2) also contained untimely reexaminations which in turn caused the rent register to match actions effective in calendar year 2022. Lastly of these files one (1) contained an income miscalculation
Criteria:
The Code of Federal Regulations 24 part 578, the Housing Authority’s Admin Plan, and specific HUD guidelines in documenting and maintaining the Continuum of Care tenant files.
Effect:
Failure to conduct timely recertifications and to properly calculate HAP can result in a misstatement of HAP expense leading to improper funding for the CoC program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding.
Recommendation:
We recommend that the Agency conduct a thorough tenant file audit of existing tenants in the Continuum of Care program. We also recommend that the Agency increase their monitoring and review of the Continuum of Care program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance.
Questioned Costs: None
Repeat Finding: Yes
Was sampling statistically valid? Yes
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.