Finding 1177957 (2025-002)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-03-11

AI Summary

  • Core Issue: Tenant rent was calculated incorrectly due to not using EIV for income verification, leading to an underpayment of $96/month.
  • Impacted Requirements: Compliance with HUD’s verification hierarchy is mandatory, specifically using EIV for income verification.
  • Recommended Follow-Up: Strengthen procedures for tenant rent calculations and ensure EIVs are consistently reviewed to prevent future errors.

Finding Text

Statement of Condition – For the Low Rent Public Housing program, we reviewed 40 tenant files (recertification files and new tenant files) for the fiscal year ended June 30, 2025. We reviewed 5 files for tenants who moved out during the fiscal year ended June 30, 2025. The selected files represent a sample of all tenant files in the two AMPS. We noted 1 instance in which tenant rent was calculated incorrectly. For this file, EIV was not used as part of the income calculation for the Move To Work (MTW) Year 1 calculation. This resulted in missed wages for the head of household. Due to this error, income was underreported in year 1 and was carried forward to year 2 when the error was discovered. The tenant should have been charged flat rent in the first year, creating an underpayment of $96/month. Since the error was carried over into the second year of the MTW program, it is reasonable for the error to be doubled due to the nature of the MTW program. Criteria – Per the Public Housing Occupancy Guidebook: 1. Section 8.2.2, “PHAs must use HUD’s verification hierarchy when verifying the family’s income, assets, deductions, and expenses…Enterprise Income Verification (EIV) is mandatory (i.e. must review EIV Income Report for all families when verifying income)”. Effect – For the files referenced above: 1. Tenant rent was incorrectly calculated, resulting in an underpayment of $96 per month for two years ($2,304 overall). Cause – Incorrect procedures were followed in regards to calculating tenant income. Recommendation – Procedures surrounding tenant rent calculation processes should be strengthened. EIVs need to be pulled and reviewed when verifying family income. Identification of a repeat finding – This is a repeat finding in the current year. Views of responsible officials and corrective action plans – The Authority agrees with this finding. Please refer to the corrective action plan on page 60.

Corrective Action Plan

MTW Income Verification and Rent Calculation Explanation of Condition: The Authority operates under HUD-approved MTW waivers, including three-year certifications. In the finding identified, Enterprise Income Verification (EIV) was not utilized during a Year 1 MTW income calculation, resulting in underreported income and an incorrect rent determination that carried forward into the second year of the MTW cycle. Corrective Actions Taken and Planned: To strengthen compliance with HUD occupancy requirements and MTW oversight standards, the Authority has implemented the following corrective actions:  The Authority has developed and implemented a formal Standard Operating Procedure (SOP) for MTW Income Verification and Rent Calculations, which requires: o Mandatory EIV review in accordance with HUD’s verification hierarchy o Documentation of EIV review in each tenant file o Supervisory review and approval of all MTW rent calculations  An internal quality control and audit review process has been established to periodically review rent calculations and certifications for accuracy and compliance.  The recertification process has been restructured so that MTW and annual recertifications are conducted primarily during April and May, allowing staff to focus on accurate income verification and calculations without competing operational demands.  Occupancy staff have received refresher training on MTW requirements, EIV usage, and HUD income verification standards.  The Authority plans to utilize MTW flexibility to implement a Standard Deduction, which will reduce calculation complexity, improve consistency, and minimize the likelihood of future errors. The Authority believes these corrective actions align with HUD monitoring expectations, strengthen internal controls, and demonstrate ongoing commitment to MTW compliance.

Categories

HUD Housing Programs

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $1.36M
14.872 PUBLIC HOUSING CAPITAL FUND $819,898
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $136,563