Finding 1164891 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2025-12-15
Audit: 374807
Organization: Pontiac Housing Commission (MI)

AI Summary

  • Core Issue: The Housing Commission is not conducting second-party reviews on annual rent certifications, leading to rent miscalculations for 6 tenants.
  • Impacted Requirements: Compliance with 24 CFR section 982.516 regarding third-party verification of tenant income and related factors is not being met.
  • Recommended Follow-Up: Strengthen internal controls to ensure proper annual reexaminations and maintain accurate documentation for all tenant files.

Finding Text

Subject: Section 8 Housing Choice Voucher Program – Tenant Eligibility and Reexaminations Federal Agency: Department of Housing and Urban Development Federal Program: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Federal Award Number and Year (or Other Identifying Number): CY 2025 Pass-Through Entity: Not applicable Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context: During audit fieldwork, 40 tenant files were reviewed for compliance with Program eligibility and reexamination requirements. It was noted the Housing Commission does not perform a second party review on annual rent certifications resulting in miscalculation of tenant rent and housing assistance payments for 6 program participants. Rent miscalculations were due to miscalculations of wages or income, incorrect utility allowances, and incorrect payment standards. Criteria: 24 CFR section 982.516 states in part “Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: (i) Reported family annual income; (ii) The value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income.” Cause: Failure to execute internal controls over the federal Eligibility compliance requirement. Effect: Non-compliance with the federal Eligibility requirement. Tenant rents may be miscalculated leading to incorrect housing assistance payments. Other notifications and documentations may be missing for program eligibility. Questioned Cost: Known and projected misstatement: $112,998 Recommendation: We recommend the Housing Commission implement and execute strengthened controls over the federal Eligibility compliance requirement to include the performance of annual reexaminations and documentation maintenance; the above discrepancies need to be addressed, and all tenant files should be reviewed for compliance.

Corrective Action Plan

1. Strengthen Internal Controls: Implement a second-party review process for all annual rent certifications to ensure accuracy in calculations. Develop a checklist for tenant file reviews to ensure compliance with 24 CFR section 982.516. 2. Staff Training: Provide targeted training for staff on federal eligibility requirements, income verification, and rent calculation processes. Include training on local demographics and common income sources to improve accuracy in income assessments. 3. Leverage Technology for Tenant File Management: Invest in software that automates rent calculations, tracks utility allowances, and flags discrepancies. Use electronic systems to maintain tenant files and ensure proper documentation. 4. Periodic File Audits: Conduct quarterly internal audits of tenant files to identify and correct discrepancies. Address any compliance issues promptly and report findings to HUD as required.

Categories

HUD Housing Programs

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $6.71M
14.879 MAINSTREAM VOUCHERS $313,238
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $96,792