Finding Text
2023-002 Eligibility
Moving to Work Demonstration Program AL No. 14.881
Material Weakness in Internal Control
Material Noncompliance
Condition: Out of an approximate population of 18,300 of Section 8 Housing Choice Voucher and
2,300 Low Rent Public Housing tenants the following deficiencies were noted:
Section 8 Housing Choice Voucher (a total of 40 tenants selected for testing):
• Thirty-five files did not have annual recertifications performed during the year,
• Nine files did not have 9886 release of information forms within 15 months of annual
recertification,
• Four files did not have an annual recertification performed with 12 months of the previous
certification,
• Three files did not have an inspection performed during the year
• Three files did not have documentation necessary to verify the reported income,
• Two files did not have a 214 declaration for a member of the household, and
• Two files did not have documentation necessary to verify custody of dependent
• Fourteen files did not contain flat rent options forms,
• Ten files did not have documentation necessary to verify the reported income,
• Seven files did not have the annual recertification performed or documented,
• Five files did not have a 214 declaration for a member of the household,
• Three files did not have support necessary to verify income allowances,
• Two files did not have 9886 release of information from within 15 months of the annual
recertification, and
• One file did not have annual recertifications performed within 12 months of the previous annual
certification.
Criteria: The Authority’s ACOP, Administrative Plan, 24 CFR 960.259, and 24 CFR 982.516 require
internal controls to be in place to ensure proper procedures are being followed in compliance with
HUD requirements regarding timely, complete, and accurate tenant files.
Context: The auditor randomly selected tenant files out of the population from each program as
outlined, which we consider to be a statistically valid sample size. The auditor reviewed the tenant
files and support to ensure that proper procedures are being followed and that the Authority is in
compliance with HUD requirements regarding timely, complete, and accurate tenant files.
Cause: The Authority experienced staffing and operational challenges during the onset of COVID-
19 and did not have the available staff to follow the established internal controls to ensure proper
compliance with regards to timely recertifications and collection of required HUD documentation to
verify eligibility and calculate accurate housing assistance payments.
Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could
result in the incorrect amount of rental assistance provided.
Questioned Costs: Unknown.
Auditor Recommendations: The Authority should reevaluate their established procedures and
controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications.
The Authority needs to correct the deficiencies noted in the tested files and consider the impact to
the rest of the population of tenant files that were not selected as part of the auditor’s sample.
Management Response: See Corrective Action Plan.