Finding Text
2023-003 Special Tests and Provisions: Rent Reasonableness
Federal Program
U.S. Department of Housing and Urban Development AL #14.871 – Significant Deficiency
Grant Award No.
ND014-Housing Choice Voucher
Federal Award Year
2023
Criteria
The Authority must maintain records to document the basis for the determination that rent to owner is
a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4,
982.54(d)(15), 982.158(f)(7), and 982.507).
Condition
We tested compliance with the Authority’s rent reasonableness forms in 40 tenant files and found that
one tenant did not have a rent reasonableness form for an increase in rent. The rent was deemed
reasonable by the Authority once noted by the auditors. We also noted two tenants whose rent was
not within 110% of the rent reasonableness comparables.
Questioned Costs
None
Context
We reviewed a sample of 40 tenant files for rent reasonableness requirements.
Effect
HAP payments could have been paid to a tenant where rent was not considered reasonable.
Cause
Upon change in rent during the term of the HAP contract, the tenant file did not contain forms
comparing the rent of like-kind units and the rent comparison was not reviewed to ensure that it was
within the required percentage.
Repeat Finding
Not a repeat finding.
Recommendation
We recommend there be a second party review of the file to ensure all appropriate documents are
included.
Views of Responsible Officials
The Authority will have a checklist on annual certifications to ensure all appropriate documents are
included in the file.