Finding Text
2025-006: Housing Assistance Payments (HAP) Condition: During testing of HAP for tenants participating in the Housing Choice Voucher program, the PHA did not maintain a HAP contract and tenancy addendum for 6 of 43 tenant files selected for the fiscal year 2025. The tenant file lacked evidence showing that the PHA maintained these legal binding documents that signifies agreement of the contract terms from all parties. Criteria: Per 24 CFR section 982.158 and 24 CFR Part 982, Subpart K, the PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register. Cause: Housing Voucher Cluster tenant files are not being maintained with complete and accurate information. Information such as HAP contracts and tenancy addendums were missing from the Housing Voucher Cluster tenant files. Effect: Without complete HAP contracts and tenancy addendums, the PHA cannot demonstrate that assisted units were under valid and enforceable agreements as required by HUD regulations. Missing documentation increases the risk of improper HAP payments, weakens the PHA’s ability to enforce landlord and tenant obligations, and exposes the agency to potential HUD monitoring findings, repayment requirements, or other compliance actions. Recommendation: We recommend that the PHA strengthen controls over tenant file maintenance to ensure that fully executed HAP contracts and tenancy addendums are obtained, retained, and properly filed for all Housing Choice Voucher participants. The PHA should: 1. Implement a standardized file checklist to confirm required documents are present prior to approving HAP payments. 2. Provide staff training on documentation requirements under 24 CFR Part 982. 3. Periodically perform internal file reviews to verify that HAP contracts and tenancy addendums are consistently maintained.