Finding 59942 (2022-002)

Finding 2022-002 ? Continuum of Care Tenant Files ? Eligibility ? Internal Control over Tenant Files ? Noncompliance and Material Weakness - ALN 14.267 Continuum of Care Program ? Subsidy Condition & Cause: We selected a sample of five (5) files for review. We noted that these tenant files were constructed for the purpose of the audit. We requested an additional sample of four (4) tenant files, and we discovered that the tenant files are not maintained contemporaneously. Of the additional sample, staff was able to locate files current through 2019 for two (2) of the tenants and was able to verify that 2021 and 2022 annual recertifications were completed in their software for three (3) of the tenants. Staff was unable to furnish the annual recertification documentation for these actions. A second review 30 days later revealed that the deficiency had not been corrected. We requested a new sample of ten (10) tenant files. Staff was unable to provide any of the tenant files in a timely manner. We reviewed the tenant ledgers and noted three (3) tenants who had ended participation but remained on the HAP register, and one (1) tenant whose ledger revealed a discrepancy with the HAP register. Criteria: The Code of Federal Regulations 24 part 578, the Housing Authority?s Admin Plan, and specific HUD guidelines in documenting and maintaining the Continuum of Care tenant files. Effect: The failure to properly document and retain tenant files can result in loss of grant funding earned by the Housing Authority. Recommendation: We recommend that the Agency conduct a thorough tenant file audit of existing tenants in the Continuum of Care program and maintain these records contemporaneously. We also recommend that the Agency increase their monitoring and review of the Continuum of Care program files to determine whether occupancy specialists need additional training or procedures added to ensure compliance. Questioned Costs: None. Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.