Finding 1153458 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2025-09-19
Audit: 366709
Organization: Cheboygan Housing Commission (MI)

AI Summary

  • Core Issue: Two tenant files lacked current income documentation needed for accurate rent calculations, while five others were not reexamined until after the fiscal year ended.
  • Impacted Requirements: Annual recertification processes were not followed, violating HUD guidelines for tenant income verification and rent calculation.
  • Recommended Follow-Up: Improve internal controls and training to ensure timely and complete tenant file updates and adherence to recertification timelines.

Finding Text

Tenant Files – Family Income Reexaminations Criteria: Housing Commissions are required to obtain supportive documentation of income from tenants on an annual basis through the recertification process. This documentation may be in the form of copies of bank statements, paycheck stubs and various receipts for certain expenses that a tenant may have. The information obtained must be entered into the Tenant Itemized Worksheet so that the tenants’ rent can be accurately calculated. Along with the information provided by the tenant, Housing Commissions are required to verify certain information through the U.S. Department of Housing and Urban Development’s (HUD) Earned Income Verification (EIV) system. The information obtained through this method should be reflected in the Tenant Itemized Worksheet so that the calculation of monthly rent subsidy can be determined accurately. In addition, a copy of the Tenant Itemized Worksheet should be included in the tenants’ file. Condition: Of the 12 tenant files that were examined, 2 of the tenant files did not contain any current information that should be used to determine a rent calculation or other information that is otherwise required for an annual recertification. Of the 12 tenant files that were examined, 5 of the tenant files did contain information that should be used to determine a rent calculation however, the reexamination did not occur until July 2025 (after the end of the Housing Commission’s fiscal year). Cause: The Housing Commission experienced turnover in key positions responsible for performing essential duties, including maintaining tenant files near the beginning of the fiscal year. This turnover resulted in the Housing Commission not having adequate controls in place to ensure that all required information was included in the tenants’ file, along with ensuring that accurate information was used in calculating the tenants’ monthly rent. Effect: As a result of this condition, the Housing Commission lacks internal controls over the process for ensuring that tenant rent is properly calculated. This situation could result in tenants being charged improper amounts for rent which in turn could result in the Housing Commission receiving inaccurate funding amounts from HUD.

Corrective Action Plan

The current Occupancy Specialist is developing a training and implementation plan to ensure that annual tenant recertifications are performed in a timely manner and in accordance will all applicable HUD requirements. The Executive Director is developing controls and procedures to ensure that tenant files are reviewed for compliance with regulatory citations and ensure that supportive documentation of income from tenants and other required paperwork is included in the tenant files.

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1153459 2025-002
    Material Weakness Repeat
  • 1153460 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $476,925
14.872 Public Housing Capital Fund $198,294
14.850 Public Housing Operating Fund $116,921