Finding Text
2025-002 – HOUSING CHOICE VOUCHER TENANT FILE DOCUMENTATION Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871 and 14.879 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirements: Eligibility; Special Tests and Provisions Criteria: HUD regulations and the Authority's Administrative Plan require an executed lease for each assisted unit (24 CFR 982.308), a documented rent reasonableness determination at initial leasing and before any increase in the rent to owner (24 CFR 982.507), annual income to be determined using gross amounts before payroll deductions (24 CFR 5.609), and utility allowances to be applied in accordance with the Authority's approved schedule (24 CFR 982.517). Condition: In our testing of the Section 8 Housing Choice Voucher program (25 tenant files), we noted two tenant files with no lease agreement, three instances in which the rent was increased with no rent reasonableness test documented, one instance in which net wages rather than gross wages were used in the income calculation, and one instance in which the utility allowance was miscalculated, resulting in an overpayment of $40 per month. Cause: Human error and employee turnover in the occupancy function. Effect: Leases and rent reasonableness determinations were not documented, and total tenant payments and housing assistance payments may be incorrectly calculated at recertification, resulting in over- or underpayments of housing assistance. Questioned Costs: Known and likely questioned costs did not exceed the $25,000 reporting threshold in 2 CFR § 200.516(a)(3). Repeat Finding: No Recommendation: We recommend the Authority retain an executed lease agreement in each tenant file, perform and document a rent reasonableness determination before each rent increase, calculate annual income using gross wages, verify utility allowances against the approved schedule, and require documented supervisory review of each tenant file and recertification. Management's Response: The Authority will strengthen its Housing Choice Voucher file review procedures to ensure executed leases, rent reasonableness determinations, gross income calculations, and utility allowances are properly documented and reviewed.