Finding 42244 (2022-002)

24 CFR sections 982.158(f)(7) provides that the Public Housing Authority (PHA) must keep records to document the basis for PHA determination that rent to owner is a reasonable rent (initially and during the term of a HAP contract). 24 CFR sections 982.54(d)(15) provides the Public Housing Authority (PHA) administrative plan must cover policies on the method of determining that rent to owner is a reasonable rent (initially and during the term of a Housing Assistance Payment contract). The Authority?s Housing Choice Voucher Administrative Plan Section 13(5)(c) provides the Authority will retain the following in the tenant file: 1. Request for Lease Approval 2. Lease 3. Inspection report(s) 4. Certification of Rent Reasonableness 5. Executed contract. The Authority could not provide the reasonable rent certifications for 44 percent of the current tenant files tested for the Housing Choice Voucher program. The tenants lacking this certification in their file had been in the program for several years or were new to the program in 2022. The Authority also could not provide the reasonable rent certification for 67 percent of the new participant tenant files tested for the Housing Choice Voucher Program. The tenants lacking this certification in their file had been admitted into the program during 2022. The failure to document rent reasonableness could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Housing and Urban Development. The Executive Director and Housing Choice Voucher employees should ensure all tenant files maintain the appropriate documentation and meet the requirements for rent reasonableness.