Finding Text
2023-001 Eligibility – Tenant Files
Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871)
Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-001 from June 30, 2022 (initially reported June 30, 2021)
Statement of Condition
Out of a total tenant population of approximately 194 vouchers, 20 files were selected for testing. Exceptions were noted as follows:
• 1 file where a math error on zero-income calculation resulted in an increase in HAP rent from $709 to $712.
• 1 file where a math error on zero-income calculation resulted in a decrease in HAP rent from $961 to $912.
• 1 file where social security income was calculated using 2022 amounts despite move-in date in February 2023. As a result, HAP rent decreased from $561 to $546.
• 1 file where social security income was calculated using 2022 amounts despite annual re-exam in February 2023. As a result, HAP rent decreased from $709 to $687.
In addition to the above, during our new admissions testing (5 tested out of 44 new admissions) we noted the following:
• 1 file that did not contain a signed lease agreement.
Criteria
24 CFR 982.516 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 administrative plan 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 and HAP payments to landlords.
Cause
Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. 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
We concur with the recommendation and have implemented various controls. A tenant file and unit quality control procedure has been developed and implemented. See corrective action plan.