Finding Text
Condition: The Organization did not obtain signed Forms 9887 - Notice and Consent for the Release of Information or 9887A - Applicant's/Tenant's Consent to the Release of Information and instead used an internally generated verification form in initial certification/recertifications that did not contain the language required by HUD for such consent forms. Criteria: Per HUD Handbook 4350.3, a tenant must sign/submit required consent and verification forms (Form HUD-9887 and Form HUD-9887-A) prior to recertification. Any owner-generated consent forms must include certain language required by HUD as detailed in the HUD Handbook 4350.3. Cause: Organizational personnel did not review the HUD Handbook 4350.3 prior to changing their process from obtaining signed Forms 9887 and 9887-A to using their internally generated consent form. Effect: Failure to use specified forms results in potential legal claims of improper access to tenant?s personal identifiable information, income data and asset information. Questioned costs: $-0- Context: We examined five tenant files which all contained a signed, internally generated verification form that did not contain the language required by HUD for such consent forms. Repeat Finding: No Recommendation: We recommend that the Organization discontinue use of the internally generated verification form immediately and obtain signed HUD Forms 9887 and 9887-A from tenant and family members prior to accessing EIV or obtaining written third-party verification of income. We also recommend an independent review of each tenant file to include examination of signed HUD Forms 9887 and 9887-A be conducted at initial or recertification by a person not directly involved in the intake or recertification process. Any discrepancies noted in this internal file review could then be corrected in a timely manner. Management should ensure that internal control procedures over use of signed, authorized consent and verification forms initial and recertification processes are strictly followed and required signed HUD Forms 9887 and 9887-A, EIV reports and other supporting documentation is maintained in each tenant?s file.