Finding Text
Finding 2025-007 –Waiting List – Eligibility – Internal Control over Waiting Lists – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing Program – Noncompliance and Material Weakness Condition & Cause: The Housing Authority was unable to provide a copy or electronic extract of the waiting list as it existed on or near the date of applicant selection or offer. The Housing Authority also could not provide a sufficient audit trail demonstrating the applicant's position on the waiting list, applicable preferences, and the basis for selection. As a result, we were unable to determine from the records maintained by the Housing Authority whether applicants and selected participants were consistently selected in accordance with applicable federal requirements, the Housing Authority's Administrative Plan, and the Admission and Continued Occupancy Policy (ACOP). The condition appears to have resulted from the absence of a documented procedure requiring Housing Authority personnel to capture and retain the waiting list, applicant ranking, applicable preferences, and selection information at or near the time each applicant is selected or offered assistance. The Housing Authority also does not have an adequate records-retention procedure specifically addressing waiting-list documentation and the preservation of an audit trail of applicant selections. Criteria: For the Housing Choice Voucher Program, 24 CFR §982.204(a) requires participants, except for special admissions, to be selected from the PHA waiting list in accordance with the PHA's Administrative Plan. Section 982.204(b) requires the PHA to maintain information that permits participants to be selected from the waiting list in accordance with the PHA's admission policies, including applicant name, family unit size, date and time of application, and qualification for local preferences. For the Public Housing program, 24 CFR §960.206(c)(1) requires the PHA to use its approved selection method when selecting among applicants with the same priority, and §960.206(c)(2) specifically requires the selection method to leave a clear audit trail that can be used to verify that each applicant was selected in accordance with the method specified in the PHA Plan. Additionally, 2 CFR §200.334 requires recipients and subrecipients to retain Federal award records, including financial, supporting, and statistical records, for the applicable retention period. Accordingly, the Housing Authority should maintain sufficient waiting-list records and supporting documentation to demonstrate that applicants were selected in accordance with applicable Federal requirements, the PHA's Administrative Plan, ACOP, and PHA Plan, including applicable preferences and selection priorities. Effect: The inability to reconstruct the waiting list and applicant selection process prevents the Housing Authority from demonstrating that applicants were selected in accordance with federal requirements and the Housing Authority's Administrative Plan and ACOP. This condition increases the risk of inconsistent treatment of applicants, inappropriate selection of applicants, failure to properly apply preferences, and undetected manipulation or alteration of the waiting list. Recommendation: We recommend that the Housing Authority establish and implement written procedures requiring the preservation of the waiting list and related applicant-selection documentation at the time of each selection. At a minimum, the Housing Authority should retain documentation showing: • The waiting list in effect at or near the date of selection; • Applicant name or identification number; • Applicant rank or position; • Applicable preferences; • Date of selection; • Basis for selection; • Date and method of offer; • Disposition of the offer; and • Any subsequent changes to the applicant's status or position on the waiting list. The Housing Authority should also establish appropriate retention periods and access controls to ensure that waiting-list records cannot be altered or deleted without an adequate audit trail. Management should periodically review waiting-list selections through its QC process to verify compliance with the Administrative Plan, ACOP, and applicable federal requirements. 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.