Finding Text
Finding 2024-001 - Moving To Work Demonstration Tenant Files - Eligibility - Internal Control over Tenant Flies - Noncompliance and Significant Deficiency
Moving To Work Demonstration - Subsidy ALN 14.881
Condition & Cause: Our review of two hundred (200) Moving To Work tenant files found that eighteen (18) files were noncompliant, representing 9% of our sample. Some files had multiple compliance issues. Specifically, we identified:
• Thirteen (13] files where the annual reexamination was completed or made effective at least two months past the due date.
• Four (4) files lacking proper verification of income or deductions.
• Three (3) files with miscalculations of annual Income.
• Four (4) files missing the EIV.
• One (1) file processed for annual reexamination without tenant involvement.
Using extrapolation, we concluded that the potential misstatement of subsidy from income miscalculations is immaterial to the financial statements.
Criteria: Compliance requirements are outlined in the Code of Federal Regulations, the Housing Authority's Admissions and Continued Occupancy Policy (ACOP), Administrative Plan, Moving To Work (MTW) Plan, and specific HUD guidelines for documenting and maintaining Public Housing and Housing Choice Voucher tenant files.
Effect: Deficiencies in tenant files can result in lost rental income due to late reexaminations, along with potential overpayments or underpayments by tenants stemming from inaccurate rent determinations. Ongoing noncompliance may also draw scrutiny from regulatory bodies, increasing the risk of financial penalties or loss of funding for the MTW program.
Recommendation: We recommend that the Agency identify the annual recert1fications that are past or near due and complete these reexaminations. We also recommend that the Agency continue their monitoring and review of the Moving To Work files to determine whether occupancy specialists need additional training or procedures added to ensure compliance.
Questioned Costs: None
Repeat Finding: Yes
Was sampling statistically valid? Yes
Views of responsible officials: The PHA agrees with the results of the audit and recommendations.