Finding Text
Finding 2024 – 001 – Eligibility
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Title: Housing Voucher Cluster
Assistance Listing Numbers: 14.871 and 14.879
Federal Award Identification Number and Year: FL080; 2024
Award Period: October 1, 2023 to September 30, 2024
Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion)
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) 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: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below:
Number of Instances Finding
4 The file is missing support for the calculation of HAP.
Of the files the Authority was able to provide. The files contained the following compliance deficiencies:
Number of Instances Finding
18 The EIV was missing from the file.
3 The file was missing the HUD-9886 authorization form.
3 The file was missing the Authority’s general release form.
12 The Authority did not review the tenant’s information on an annual basis
5 The allowable expenditures included in the file were not included on the 50058
9 The HAP paid was understated
2 The HAP income information reported in the 50058 did not agree to support.
Questioned Costs: $12,428
Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted
above.
Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan.
Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the
calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058.
Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001.
Recommendation: To ensure compliance with federal requirements, we recommend the Authority
takes the following actions:
1. Conduct training for program staff on eligibility documentation requirements and program rules.
2. Initiate internal audits of tenant files to identify and correct documentation issues proactively.
3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues.
Views of Responsible Officials: There is no disagreement with the audit finding.