Finding 402813 (2023-001)

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files - Noncompliance & Significant Deficiency Housing Choice Voucher Program – ALN 14.871 Condition & Cause: We reviewed forty-two (42) Housing Choice Voucher tenant files and noted eleven (11) files that were out of compliance, or 26.2% of our sample. The discrepancies noted in the files are as follows: • Three (3) instances of an annual reexamination that was completed late; • Three (3) instances of HAP register disagreement due to delayed End of Participation (EOP) processing; • Three (3) instances of improper income verification; • Four (4) instances of omitted zero income procedures outlined in the Agency’s Admin Plan; • One (1) instance of missing annual inspection documentation; • One (1) instance of missing HUD form 9886; and • Two (2) instances of missing EIV We reviewed the HAP ledgers for the three (3) files which did not agree with the HAP register due to a delay in processing the participant’s EOP. In each case, we found that the landlord did not receive HAP improperly. We noted that during the period in review, the Agency experienced an abundance of staff turnover. This included Executive staff and the departments that oversee voucher administration. We believe this contributed to the compliance discrepancies. Criteria: The Code of Federal regulations, the Housing Authority Administrative Plan and specific HUD guidelines in documenting and maintaining Housing Choice Voucher tenant files. Effect: Failure to conduct timely recertifications and to properly calculate annual income can result in a misstatement of HAP expense leading to improper funding for the HCV program. Misstatements of HAP may also cause an undue financial burden to the participant, which goes against the mission of the Agency. Additionally, noncompliance can result in a decrease of vouchers or loss of program funding. Recommendation: We recommend that the Agency conduct a tenant file audit of existing tenants in the HCV program to determine the extent of any additional misstatements of HAP expense. We also recommend that the Agency increase their monitoring and quality control review of the HCV program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Our experience with agencies that increase monitoring and review of the files is that there are dramatically decreased error rates. 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.