Finding Text
Finding 2023-03:
Condition: The Organization did not comply with the HUD requirement to obtain proof that tenant
meets disability requirements for residency prior to admitting two applicants.
Criteria: Section 811 of the National Affordable Housing Act provides funding for housing for persons
with disabilities. To qualify as disabled, the household must consist of at least one person who is an
adult (18 years or older) with a disability, two or more persons with disabilities living together, or a
surviving household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section
891.505). Residents must also qualify as very low-income households to be eligible (42 USC 8013).
Eligibility is only determined at move-in or at initial certification except in circumstances whereas
family composition changes after initial occupancy a determination must be made as to whether the
remaining member of the household will be eligible to receive assistance.
Cause: Failure to follow internal control procedures during initial certifications of prospective tenants.
Effect: Ineligible applicants were allowed to become tenants and receive assistance.
Questioned costs: $1,924
Context: We noted no proof of qualifying disability in examination of two tenant files on two new
tenants. Repeat Finding: No
Recommendation: We recommend that the Organization require any personnel performing initial
certifications or recertifications to undergo HUD 811 training regarding the intake process and program
requirements prior to performing any initial certifications. Additionally, we recommend a second
person in the housing office review each potential tenant’s file to ensure completeness and compliance
with HUD 811 eligibility and documentation requirements prior to signing the new/amended lease
agreement.
Reporting Views of Responsible Officials: Management agrees with the finding and will begin an
independent review of each tenant file to include examination of proof of disability paperwork to
determine if there are any discrepancies and take corrective measures. Leasing office staff will
undergo additional HUD 811 training regarding the initial and recertification process. Additionally,
management is staffing the property with a dedicated property manager that will be responsible for
reviewing tenant files for compliance with HUD procedures including eligibility requirements and
ensure supporting documentation is maintained in each tenant’s file prior to signing new or amended
leases. Management has requested proof of disability from the tenant that satisfies HUD guidelines
and will not renew lease if it is not received.