Finding Text
Finding 2025-005 – Tenant Files – Eligibility – ALN 14.871 Housing Choice Voucher Program – Noncompliance and Material Weakness Condition & Cause: The Housing Authority's tenant files did not consistently contain the documentation necessary to demonstrate compliance with federal program requirements for the Housing Choice Voucher program. The exceptions identified indicate deficiencies in the Housing Authority's file review, documentation, and quality control processes. We reviewed 25 Housing Choice Voucher participant files and identified noncompliance in 16 files. Some files contained more than one exception. The following conditions were identified: • Three files lacked adequate or proper verification of income; • Two files contained income calculation errors; • One file did not contain adequate verification of income deductions; • Seven files lacked required identification documentation for at least one household member, including Social Security cards and/or birth certificates; • Three files lacked declarations of citizenship; • Two files did not contain the HAP contract for the assisted unit; • One file contained an outdated utility allowance on the HUD-50058; • One file lacked a complete authorization for release of information; and • One file did not contain the required EIV report at annual reexamination. Five of the 25 files reviewed, or 20 percent of the sample, contained exceptions directly related to adjusted annual income. The deficiencies appear to have resulted from inadequate management oversight, insufficient documented Standard Operating Procedures (SOPs), and the absence of an effective Quality Control (QC) process for reviewing tenant files. Management informed us that, as of the audit fieldwork date, the Housing Authority had begun developing SOPs and QC procedures. Criteria: The Housing Choice Voucher Program requires PHAs to maintain documentation supporting family eligibility, income, deductions, family composition, and continued assistance. Under 24 CFR §982.201(a), a PHA may admit only eligible families to the Housing Choice Voucher Program. Eligibility includes applicable income eligibility requirements and citizenship or eligible immigration status. 24 CFR §982.516(a) requires the PHA to conduct an examination of family income and composition at least annually and obtain and document third-party verification of reported annual income, assets, expenses related to deductions, and other factors affecting adjusted income, unless an allowable exception applies. Section 982.516(f) further requires the PHA to establish procedures to assure that income data is complete and accurate and requires corrective action when errors are identified. For citizenship and immigration status, 24 CFR §5.508 requires each family member to submit appropriate evidence of citizenship or eligible immigration status as a condition of assistance or continued assistance under a Section 214-covered program. HUD requires PHAs to use the Enterprise Income Verification system in their day-to-day operations. HUD explains that EIV is used to supplement and verify tenant-provided income information during required annual reexaminations and to reduce subsidy payment and administrative errors. Effect: The deficiencies increase the risk that participants may receive assistance for which they are not eligible or may receive assistance in amounts that are not properly calculated. Inadequate documentation also prevents the Housing Authority from demonstrating compliance with federal program requirements. In addition, the absence of timely inspections and required tenant documentation increases the risk that housing units may not meet program requirements and that participant eligibility and continued assistance may not be properly supported. Recommendation: We recommend that the Housing Authority complete and implement comprehensive SOPs and QC procedures for both the Housing Choice Voucher and Public Housing programs. At a minimum, the procedures should establish: 1. Required documentation for initial eligibility and annual reexaminations; 2. Required income and deduction verification procedures; 3. Procedures for reviewing EIV information; 4. Required citizenship and identity documentation; 5. Required HAP contracts and other program documents; 6. Procedures for maintaining current utility allowances; 7. Annual inspection procedures and supervisory monitoring; 8. Lead-based paint documentation requirements; 9. Required annual applications for continued occupancy; 10. Supervisory review of tenant files before completion of annual reexaminations; and 11. Periodic independent QC reviews with documented corrective action. Management should also review the files identified during the audit and correct any eligibility, rent, assistance, inspection, or documentation deficiencies. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.