Finding Text
2022-002 Eligibility ? Source Documentation Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Housing and Urban Development Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Award Number and Year: Assistance Listing Number Award Number Year 14.871 MN163VO/MN163AF 2022 14.871 MN163EP/MN163EI/MN163ES/MN163EF/MN163EH 2022 14.879 MN163DV/MN163F 2022 Pass-Through Agency: N/A ? Direct Criteria: Title 2 U.S. Code of Federal Regulations ? 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per Title 24 U.S. Code of Federal Regulations ? 982.553(a)(2), each member over the age of 18 is subject to a criminal background check prior to admission into the program. In addition, Title 24 U.S. Code of Federal Regulations ? 5.508 states that for each family member who contends that he or she is a U.S. citizen or a noncitizen with eligible immigration status, the family must submit to the responsible entity a written declaration, signed under penalty of perjury, by which the family member declares whether he or she is a U.S. citizen or a noncitizen with eligible immigration status (Section 214 Form). For each child, the declaration must be signed by an adult residing in the assisted dwelling unit who is responsible for the child. Public Housing Authorities are required by Notice PIH 2010-19 to provide the ?Debts Owed to Public Housing Agencies and Terminations? notice to all applicants and program participants over the age of 18, and all such individuals, are required to acknowledge receipt of the notice by signature located on the notice itself. Condition: A sample of 40 case files were reviewed, and the following issues were identified: ? Seven case files were missing documentation or evidence that a criminal background check was performed for one or more adult members of the household. ? Two case files were missing a family member on the Status 214 Citizenship Form. ? Four case files were missing the "Debts Owed" form for one or more adult members of the household. Questioned Costs: None. Context: HousingPro is the system used by the Metropolitan Council Housing Redevelopment Authority to calculate the monthly Housing Assistance Payments for the Housing Choice Voucher program participants and to document and support eligibility determinations. Proper input of information into the system and documentation retention is an important function to ensure accurate and proper eligibility determination and calculations of Housing Assistance Payments. The deviations identified did not impact eligibility or result in an incorrect level of benefit amount. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Errors in eligibility-determining factors increases the risk that a program participant will receive benefits when they are not eligible or are paid at an incorrect benefit amount. Cause: Personnel entering case information into HousingPro did not ensure necessary documentation was completed and/or maintained. Recommendation: We recommend that the Metropolitan Council implement additional procedures to provide reasonable assurance that all necessary documentation is maintained supporting compliance with federal regulations. View of Responsible Official: Concur.