Finding 9518 (2022-002)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2024-01-23

AI Summary

  • Core Issue: The Public Housing Authority (PHA) failed to obtain necessary signatures on HUD-9886 forms from all household members over 18, leading to noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 24 CFR sections regarding tenant documentation and verification processes was not met, specifically concerning the authorization for release of information.
  • Recommended Follow-Up: Assign a designated reviewer to check a sample of recertified tenant files monthly to ensure all required HUD forms are properly signed and updated.

Finding Text

Federal agency: Housing and Urban Development Federal program title: Public Housing Program Assistance Listing Number: 14.850 Federal Award Identification Number and Year: AL086, 2022 Award Period: 1/1/2022-12/31/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 960.259). (2) 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). (3) Determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5, Subpart F (24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions – Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR sections 960.253, 960.257, and 960.259). Condition: During the testing of 40 Public Housing tenant files, a compliance deficiency was noted. Of the tenant files provided, we noted that 2 of the HUD-9886 forms were not signed and/or were missing signatures from household members over the age of 18. Questioned Costs: None Context: Of the 40 tenant files tested, two tenant files contained exceptions from the prescribed controls resulting in noncompliance. Effect: The Authority is not in compliance with federal regulations regarding signed “Authorization for Release of Information/Privacy Act Notice” form HUD-9886 for the recertification tested. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: The Authority failed to ensure that the files contained current and updated HUD-9886 forms that included signatures for all members in the household above the age of 18. Repeat Finding: No Recommendation: The Authority should designate one person to review a sample of the files that have been recertified each month, to ensure that all the tenant files contain the necessary updated HUD forms. Views of responsible officials: There is no disagreement.

Corrective Action Plan

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-002-Eligibility Public Housing - Assistance Listing No. 14.850 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Public Housing Property Managers will sample a percentage of monthly recertifications to ensure that tenant files contain the necessary updated HUD forms. Name(s) of the contact person(s) responsible for corrective action: Hannah Gore, ED and Public Housing Property Managers Planned completion date for corrective action plan: December 31, 2023 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call the Executive Director at (205) 244-1348

Categories

HUD Housing Programs Eligibility Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 585960 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $17.70M
14.850 Public and Indian Housing $3.03M
14.267 Continuum of Care Program $2.84M
14.872 Public Housing Capital Fund $640,314
14.879 Mainstream Vouchers $281,925
14.871 Emergency Housing Vouchers $200,685
14.896 Family Self-Sufficiency Program $140,000