Finding Text
2024-008 Character Investigations This is a repeat finding. The prior-year’s auditing finding number is 2023-008. Condition: The Housing Authority is not performing or documenting character investigations (background checks) on employees. Criteria: While federal law does not require housing authorities to conduct pre-employment background investigations, HUD strongly encourages organizations to implement appropriate integrity screening procedures as part of a sound hiring process. Additionally, recognized human resource management and public-sector governance best practices recommend that employers conduct and document thorough pre-employment screening to assess an applicant's integrity, reliability, and suitability for positions of trust. Such best practices include obtaining and documenting professional reference checks, verifying prior employment and educational credentials, conducting criminal background screenings when appropriate and legally permissible, and maintaining sufficient documentation to support hiring decisions. These procedures provide reasonable assurance that individuals selected for employment meet the standards necessary to perform their duties effectively and ethically. Adherence to these practices helps mitigate the risk of fraud, misconduct, workplace violence, reputational damage, and other operational risks while promoting accountability and safeguarding organizational assets, residents, and employees. Cause: No written policies and procedures to guide Human Resources personnel. Effect: Individuals with criminal histories that would preclude them from being hired into certain positions (with access to cash, access to personally identifiable information and/or close proximity to children and the elderly) may be hired for such positions. Recommendation: Adopt and implement policies over the performance of character investigations, the filing of character investigations and the criteria to be used to preclude the hiring of individuals for certain positions. Views of Responsible Officials: See Corrective Action Plan.