Finding Text
HVC Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: NE 001; 2025 Award Period: January 1, 2025 – December 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). (3) Determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (6) Re-examine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Condition: Out of 60 tenant files tested for eligibility, 17 tenant files contained errors or missing required documentation. Questioned Costs: Actual, likely and projected questioned costs were under $25,000. This was based on the expected HAP impact calculated on the untimely recertifications. Context: Out of 60 tenant files tested, exception were noted in the following 17 tenant files: • 5 instances where the tenant file did not contain a signed HUD-9886 or HUD-9886-A form by all members of the household over 18. • 1 instance the tenant file did not contain a signed general release form by all members of the household over 18. • 13 instances where the HUD-50058 recertification was not performed annually. Cause: The Authority failed to implement the internal controls designed to ensure compliance with eligibility requirements were met. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements determined by HUD. Errors in eligibility could result in incorrect HAP payments. Repeat Finding: The finding is a repeat of a finding in the immediate prior year. Prior year finding number was 2024-002. Recommendation: We recommend the Authority: • Review and revise its eligibility determination procedures to ensure full compliance with HUD regulations; • Maintain a schedule of tenants and housing specialists to ensure that recertifications are performed annually; • Train staff on proper documentation and verification protocols for items listed in the HUD-50058 form; • Update its Administrative Plan to reflect accurate and timely eligibility screening procedures. Views of Responsible Officials: There is no disagreement with the audit finding.