Finding Text
14.850 Public and Indian Housing
2024-001:
Condition The Authority is responsible for complying with Uniform Guidance (2 CFR Part 200) and the U.S. Department of Housing and Urban Development (HUD) regulations, and is required to maintain complete and accurate tenant files that substantiate tenant eligibility, and compliance with specific program requirements.
Criteria During the annual recertification process, the Authority is required to complete a physical condition inspection report, in accordance with internal policy and the special tests and provisions section of 24 CFR section 5.703.
Context In reviewing and testing tenant files, 2 out of 40 sample tenant files (5%) were missing the annual physical condition inspection report that is necessary to maintain tenant eligibility and compliance with specific program requirements.
Cause The Authority indicated the deficiencies were primarily due to significant staff turnover and oversight in maintaining and reviewing tenant files. The existing internal controls were insufficient to ensure compliance with both internal and HUD’s documentation requirements.
Effect The deficiencies in maintaining complete tenant files could lead to potential noncompliance under the eligibility and special tests and provisions requirements of the Public and Indian Housing program. This might result in questioned costs and could jeopardize future funding from HUD.
Recommendation We recommend the Authority conduct a periodic internal review process to ensure that all tenant files are complete and in compliance with federal requirements, including development of procedures for routinely updating tenant files and rectifying any identified deficiencies in a timely manner.
Planned Corrective Action The Authority will have all tenant files reviewed after an annual to ensure accuracy of documentation and the files. The Program Supervisor will receive a list of all annuals each Leasing Specialist will be doing for the month. The Supervisor will have a checklist that they will verify and sign off on that all files are complete and in compliance with necessary requirements.