Finding 1145779 (2024-004)

Incomplete Tenant File Documentation and Inconsistencies in MTW Housing Assistance and Public Housing Records (ALN 14.881) Condition: During tenant file testing for both the Housing Choice Voucher (HCV) and Public Housing (PH), components of the Moving to Work (MTW) Demonstration Program, we identified multiple deficiencies in the Authority’s documentation and reporting practices:1. For six out of sixteen HCV tenants, the Authority was unable to provide the tenant file for review. 2. Among the files that were available, several lacked required documentation for the required period to support continued occupancy, rent adjustments, reexaminations, income verification, and inspections. 3. Additionally, variances were noted between the amounts reported on HUD Form 50058 and the actual HAP/UAP disbursements made.Criteria: Under the MTW Operations Notice (85 FR 10232), 2 CFR §200.302, and HUD regulations at 24 CFR §982, public housing authorities must maintain complete and accurate tenant files and ensure that all disbursements are supported by appropriate documentation. HUD Form 50058 must accurately reflect the tenant’s eligibility and payment information, and all payments must be consistent with the amounts authorized and documented in the tenant file. Cause: The Authority lacked effective internal controls and monitoring procedures over tenant file documentation, rent calculation, inspection recordkeeping, and HUD form completion and retention. Effect: Incomplete tenant files and discrepancies between reported and actual disbursements impair the Authority’s ability to demonstrate compliance with HUD requirements. These issues increase the risk of improper payments, audit findings, and potential administrative sanctions. Questioned Costs: $462,754 Recommendation: The Authority should strengthen its internal controls over tenant file maintenance and disbursement reconciliation. All tenant files should be reviewed for completeness, and missing documentation should be obtained. Disbursements should be reconciled to HUD Form 50058 and verified against supporting documentation. Staff should receive training on documentation and compliance requirements under the MTW HAP program, and periodic quality control reviews should be implemented to ensure ongoing compliance. Reply and Corrective Action Plan: The Authority will implement a process to improve tenant file management, ensure complete documentation for occupancy and eligibility, and reconcile disbursement variances with HUD Form 50058 to strengthen compliance with MTW Housing Assistance Payment requirements.