Finding Text
2022-002 ELIGIBILITY ? INTERNAL CONTROL AND COMPLIANCE (SIGNIFICANT DEFICIENCY AND OTHER MATTERS) Federal Program Title: ALS 14.871 Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Questioned Costs: $41 Condition: During our single audit testwork over eligibility of payments to participants, we noted the following: 1) For 1 of the 40 tested samples we noted that department did not maintain the appropriate documentation within the participant files to support the use of Enterprise Income Verification (EIV) was completed. 2) For 1 of the 40 tested samples we noted that the department used an incorrect amount when performing the calculation of income which resulted in an overpayment of Housing Assistance Payment (HAP) to the participant. The samples were statistically valid samples. Criteria: The following criteria are applicable for the above conditions, respectively: 1) Per 24 CFR 5.233(ii) the entity is required to use EIV when performing assessements of eligibility of participants. 2) 24 CFR 982.516 outlines the requirements for calculation of the family income. This outlines that PHA is responsible for appropriately calculating at either initial or rexamination the income determination. Context/Cause: The documentation for income verification and calculation is maintained by a program staff that is assigned to the case. 1) The program specialist did not maintain the appropriate documentation in the file for the EIV for the case. 2) The program specialist did not appropriately calculate the family income. The program specialist did not use the gross social security benefit, but the net benefit. Additionally, there was an reduction adjustment to income of $135 that was not substantiated within the file. Effect: Possible and actual noted noncompliance with applicable regulations and HUD requirements, possible undercharges, and possible and actual overcharges to the grants. Repeat Finding: N/A ? New 2022. Recommendation: We recommend that the County continue to review internal processes and policies to better ensure compliance with HUD requirements for participant eligibility. Additionally, we recommend the County to provide training to staff to better ensure consistency in program participant file documentation and compliance with documentation required by HUD. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. All program staff will attend a HUD approved HCV and rent calculation training to ensure compliance with all HUD regulations including EIV and rent calculations. This training will be taken by all staff no later than June 30, 2023. In addition, a training will be held to review our internal checklist to ensure consistency of documentation retained in each client?s file. All staff will be trained on our checklist no later than January 31, 2023.