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2025-002 FEDERAL COMPLIANCE – TENANT DOCUMENTATION Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility and Special Provisions Criteria: HUD requires Public Housing Authorities (PHA) to properly document the eligibility of tenants, properly calculate benefits based on tenant income and determine rent is reasonable. Condition: During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • Missing or incomplete HQS/inspection documentation (reports, checklists, or proof of passing; some years not uploaded). • Voucher / Form 50058 (Family Report) missing or incomplete, including support for payment standard/bedroom size used. • Utility reimbursement (UR) and HAP payment changes not supported with required documentation or clear interim/recert support. • Rent reasonableness documentation missing or incomplete, including missing conclusion that rent was reasonable. • Other required file items missing, such as HAP contract, lease pages, eligibility verifications (e.g., birth verification), landlord certification forms, and zero-income forms. Cause: According to the PHA director, these issues were primarily caused by a server crash with the required documentation being unrecoverable. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes, 2024-002 Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: The PHA began forwarding requested documentation to the auditors before the server crash impacted its ability to locate and respond to file requests. Once APD recovered the files in September, the PHA resumed providing recovered documentation to fulfill the auditors’ request. To date, the PHA is unable to locate three documents that were originally requested before the crash. The PHA is continuing to sort and review the 12,000+ files that were recovered and will provide any additional responsive documents if they are located. The PHA has revised its recertification/application intake procedures. If a participant submits a recertification packet/application that is incomplete, the PHA will not accept it for processing. Packets must be submitted complete, including all required supporting documentation, before the staff will move forward. In addition, the PHA has strengthened documentation controls to improve file integrity and retrieval going forward. These actions include: • Required intake checklist: The PHA uses a standardized checklist to verify that all required forms and documents are received before a packet is accepted. • File completeness review: The PHA conducts a second-level review to confirm documentation is present and appropriately filed/scanned before final processing. • Standardized scanning and labeling: The PHA scans and labels documents consistently to ensure they can be efficiently located and reproduced for monitoring or audit requests. • Ongoing reconciliation of recovered files: The PHA continues reviewing the 12,000+ recovered files and will provide any additional responsive documents if located, while also using this process to identify and address any gaps in recordkeeping practices. These measures are intended to reduce missing documentation, strengthen file retention practices, and ensure the timely retrieval of records in the future.