Finding Text
2025-001: Non-Compliance with Waiting List Requirements Condition: Housing Voucher Cluster waiting list is not being maintained in accordance with federal requirements or its own Administrative Plan. Applicant names were not removed when required, and updates to applicant information were not consistently recorded or verified. Criteria: Per 24 CFR 982.54(d)(1), the Public Housing Agency (PHA) Administrative Plan must include policies for managing the Housing Choice Voucher (HCV) waiting list, including the method for organizing, applying selection preferences, maintaining the list, and updating applicant information. Additionally, 24 CFR 982.204(a) requires the PHA to select applicants from the waiting list in accordance with the PHA’s written policies and applicable regulatory requirements. PHA policy further requires periodic updating of the waiting list, removal of applicants who fail to respond to update notices, and proper documentation of all additions, removals, and changes. Cause: The PHA did not maintain the waiting list in accordance with federal requirements or its own Administrative Plan. Applicant names were not removed when required, and updates to applicant information were not consistently recorded or verified. These deficiencies indicate that internal controls over the waiting list process were not operating effectively, and staff did not adhere to established procedures. Effect: Because the waiting list was not adequately updated and applicant names were not removed as required, auditors could not determine whether applicants were selected for admission in the correct order or in compliance with federal regulations and PHA policy. This increases the risk of improper or inequitable admissions decisions, inaccurate reporting, potential Fair Housing implications, and an inability to substantiate compliance with mandatory procedures. Recommendation: The PHA should strengthen internal controls over waiting list management. Actions should include: 1. Updating the waiting list to ensure all information, removals, and changes are accurately documented. 2. Implementing or reinforcing procedures to ensure timely removal of applicants who fail to respond to update notices or are no longer eligible. 3. Providing staff training on federal requirements and PHA policy. 4. Establishing periodic monitoring to verify compliance and documentation accuracy.