Finding Text
2022 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Public and Indian Housing Assistance Listing Number: 14.850 Federal Award Identification Number and Year: 2022 Award Period: January 1, 2022 through December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). Per 24 CFR part 5, the Authority must obtain documentation and verification of citizenship and eligible immigration status for all household members. Condition: During our testing of 40 tenant files for eligibility requirements, the Authority was unable to locate complete support for 1 tenant file. They were unable to locate the following: - Birth certificates for all dependents - Declaration 214 form for all members of the household - Copy of the completed annual recertification checklist Additionally, the third party support provided for their wages did not agree to the wages listed on the HUD-50058. Questioned costs: $31 Context: Testing of 40 Public and Indian Housing tenant files identified an exception in 1 file. In this instance, the file did not contain full support for the recertification tested and did not have income support that matched the income listed in the HUD-50058. Cause: The one instance of missing information and support out of the forty tenant files sampled was contributed to by staffing transition together with COVID dynamics, and the corresponding regulatory waivers, where families self-certified annual income and family composition or were orally interviewed as opposed to in-person interviews with full verification of reported family circumstances with documented support. This nearly two-year period where full verification was not required resulted in unintended consequences and a changed tenant dynamic once the regulatory waivers expired at the close of 2021. Additionally, significant staff turnover resulted in employees hired during the COVID waiver period having to adjust to the guidelines which, though they existed previously, were not effective during their tenure. Stated clearly, some of these individuals had never conducted recertifications in the pre-COVID process. This transition compounded the problem, and while human error may have also been a factor in this instance, going forward the Authority expects to meet the recertification requirements. Effect: The Authority is not in compliance with HUD guidelines for family reexaminations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure all necessary documentation is maintained and accurate. Views of responsible officials: There is no disagreement with the audit finding.