Finding Text
2022-004 Eligibility: Public Housing Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat Finding from June 30, 2021 reported as Finding 2021-002 Condition: Out of a total tenant population of approximately 300 tenant files, 25 files were selected for testing (but stopped testing after 18 files due to the volume of errors). Exceptions were noted as follows: ? 1 tenant file where the Authority was unable to locate and therefore could not test items such as Form 9986, personal declaration form, birth certificates, social security cards, income and deduction support, and EIV verification. The Authority indicated it was recreating the file. ? 2 tenant files with missing 214 affidavits. ? 1 tenant file where the 214 affidavit was not signed. ? 5 tenant files where the personal declaration form was not in the file. ? 1 tenant file where the Form 9886 was not in the file. ? 1 tenant file where the Form 9886 was signed approximately 3 months after the recertification date. ? 4 tenant files with income issues which may have changed the tenant rent amount: o 1 file where there was no support for the family contribution listed on the 50058. o 1 file where there was no support for the child support listed on the 50058. o 2 files where general assistance income (food stamps) was listed as income on the 50058 but should have been excluded. ? 4 tenant files with deduction issues which may have changed the tenant rent amount: o 1 file where the utility allowance of $91 was not on the 50058. This was corrected subsequently on an interim certification. o 1 file where the ?Disclosure of Information? form listed weekly child care expenses, but no child care expenses were deducted on the 50058 and there was no documentation or support in the file explaining if the child care expenses were deductible. o 1 file where the ?Recertification Summary? form listed weekly medical expenses, but no medical expenses were deducted on the 50058 and there was no documentation or support in the file explaining if the medical expenses were deductible. o 1 tenant file where the prior year utility allowance of $82 was used instead of the current utility allowance of $90. ? 1 file where the tenant is paying a flat rent of $686. However, the flat rent appears to be the amount from the previous year and it doesn?t appear that a current flat rent study was conducted or approved. ? 1 file where the dependent date of birth listed on the 50058 did not agree to the birth certificate. ? 2 files where the birth certificates were missing. ? 2 files where the social security cards were missing. ? 1 file where the EIV was not in the file. Criteria: 24 CFR 960.253 - 259 requires internal controls to be in place to ensure compliance with HUD requirements, as well as complete and accurate tenant files. In addition, the Authority?s Admissions and Continued Occupancy Policy (ACOP) also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertification, which could result in incorrect total tenant payments for rent. Cause: Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Auditor?s Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority agrees with the finding and has taken corrective action. See the ?Action Taken? on the Corrective Action Plan.