Finding Text
2022-003 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows:
• 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23:
o 1 error for miscalculation of the tenant’s social security income
o 1 error for miscalculation of the tenant’s medical expense.
• 1 tenant file had the following errors:
o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status.
o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent.
• 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent.
• 1 tenant file had the following errors:
o The 50058 form reported the wrong number of bedrooms in the unit.
o The tenant did not sign the lease agreement.
• 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent.
• 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11:
o Miscalculation of the tenant’s social security income
o Miscalculation of the tenant’s medical expense.
• 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8:
o Miscalculation of the tenant’s supplemental security benefit
o Miscalculation of the tenant’s utility allowance amount.
o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form.
o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status.
o Member of the household, over the age of 18, did not sign and date the 9886 form.
o The HAP contract was not signed and dated by the Authority.
• 1 tenant file error due to a missing signed lead base paint form.
• 1 tenant file had the following errors:
o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8.
o The lease agreement’s signature page is missing.
• 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date.
• 1 tenant file had the following errors:
o Missing HAP contract and lease agreement.
o Missing rent reasonableness support.
• 1 tenant file error for missing rent reasonableness support.
• 1 tenant file had the following errors:
o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent.
o The lease agreement’s signature page is missing.
• 1 tenant file had the following errors:
o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2.
o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent.
o The tenant’s name was reported incorrectly on the 50058 form.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status.
o A member of the household over the age of 18 didn’t sign and date the 9886 form.
o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12.
o Missing rent reasonableness support.
o The landlord did not sign the lease agreement.
• 1 tenant file had the following errors:
o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status.
o Missing support for total annual unreimbursed childcare costs.
o Missing support for total annual unreimbursed medical expense.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.