Finding Text
Assistance Listing Number, Federal Agency, and Program Name 14.850, U.S. Department of Housing and Urban Development, Public and Indian Housing
Federal Award Identification Number and Year N/A
Pass through Entity N/A
Finding Type Significant deficiency and material noncompliance with laws and regulations
Repeat Finding Yes
2022-001
Criteria As a condition of a tenant's admission or continued occupancy, the Commission is required to adjust the tenant rent and housing assistance payment as necessary using documentation from third party verification (24 CFR Sections 960.253, 960.257, and 960.259).
Condition For 8 tenants in a sample of 23 tenants selected in conjunction with eligibility testing, the Commission failed to either correctly calculate family income composition or did not retain required documentation supporting eligibility determinations.
Questioned Costs N/A
Identification of How Questioned Costs Were Computed N/A
Context During testing of 23 tenants selected for eligibility testing, we identified the following issues:
For 2 of the 23 tenants selected, the Commission did not retain the appropriate consent from the tenant to verify third party income.
For 1 of the 23 tenants selected, the Commission did not retain documentation of the tenant's ID/Social Security number to independently verify citizenship.
For 6 of the 23 tenants selected, the Commission incorrectly calculated the tenants' annual income due to administrative errors leading to inputs in to the calculation not agreeing to the underlying third party income verification received.
Cause and Effect Controls to ensure initial eligibility determinations and eligibility recertifications were performed in accordance with federal regulations were not consistently followed. This led to an inability by the Commission to identify all timeliness and retention issues, as well as family income composition calculation errors. Recommendation The Commission should ensure that it has the appropriate controls and personnel in place to perform all eligibility determinations and recertifications in accordance with federal regulations. Controls should include proper reviews of the recertification documentation to ensure that family income composition is properly calculated, and that appropriate documentation is retained in the tenant's file for third party verification consent and to support the eligibility determinations made.
Views of Responsible Officials and Corrective Action Plan The Commission is implementing a plan to internally audit 100 percent of all tenant files in the Low Income Public Housing (LIPH) program. This plan involves both the use of experienced employees and an outside consultant. As part of the plan, a system for timely updating and automating files will be implemented, recurring compliance issues will be identified and addressed, and expanded formal training and specific training will take place from the consultant. An additional level of review will also be put in place to assist in catching any inconsistencies in the process. The Commission has also added an operations manager and a staff person to oversee the LIPH program. These additional staff will be incorporated into the overall plan to strengthen controls to ensure program compliance.