Finding Text
2024-002 Public Housing Tenant Files: Eligibility
Program: U.S. Department of HUD: Public and Indian Housing Program (ALN #14.850)
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Statement of Condition: We tested 19 out of approximately 181 tenant files and discovered the following errors:
• 1 tenant file had the following error:
o A dependent of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the dependent’s birth certificate, the dependent is a U.S. citizen.
• 1 tenant file had the following error:
o The tenant’s childcare income was calculated and reported incorrectly on the 50058 form in the amount of $2,472. Correcting the tenant’s childcare income to $2,237 would decrease the tenant’s rent by $6.
• 1 tenant file had the following error:
o Support for the tenant’s wage income could not be located. It’s unknown as to whether the tenant’s wage income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly.
• 1 tenant file had the following error:
o The tenant’s social security income was carried forward from the prior year in the amount of $11,172. Correcting the tenant’s social security income to $12,144 for the annual recertification period tested, would increase the tenant’s rent by $25.
• 1 tenant file had the following error:
o The tenant’s social security income was carried forward from the prior year in the amount of $12,456. Correcting the tenant’s social security income to $13,548 for the annual recertification period tested, would increase the tenant’s rent by $27.
• 1 tenant file had the following error:
o The tenant’s other source income of $720 was carried forward from the prior year. The tenant’s income was not updated for the annual recertification and it’s unknown as to whether the tenant’s other source income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly.
Criteria: Per 24 CFR 982.516, internal controls are required to ensure full compliance with HUD requirements and the integrity of tenant files. Furthermore, the Authority’s ACOP Plan mandates adherence to established procedures for the accurate determination of tenant income and rent, with comprehensive documentation maintained within tenant records.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of HUD requirements regarding eligibility and tenant recertification, which could result in incorrect total tenant payments for rent.
Cause: Procedures to ensure compliance with all of HUD requirements were not being carefully followed.
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. The Authority has an established review, oversight and training process for all of its staff and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed.