Finding Text
2023 – 003 – Housing Voucher Cluster Eligibility
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Housing Voucher Cluster
Assistance Listing Number: 14.871/14.879/14.EHV
Federal Award Identification Number and Year: VA003, 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion)
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 the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230).
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 982.516). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). (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 section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (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 section 982.516). Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K).
Condition: The Authority did not have sufficient internal controls over eligibility determinations to ensure compliance with HUD requirements.
Context: During our testing of 40 tenants for eligibility requirements, we noted the following:
- 3 of 40 tenant files tested did not have a signed Declaration 214 for all members of the household
- 11 of 40 tenant files tested did not have proper support for income
- 6 of 40 tenant files tested did not have proper support for assets
- 4 of 40 tenant files tested did not have proper support for expenses (deductions)
- In total, 15 of 40 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses
- 5 of 40 tenant files tested did not have a signed HUD-9886 in place
- 11 of 40 tenant files tested did not have a HAP contract/HAP contract amendment on file
- 2 of 40 tenant files tested had a HAP made on their behalf that did not match the HUD-50058 in effect
Questioned costs: $45,541
Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff.
Effect: The Authority is not in compliance with HUD regulations over Eligibility, which could have an impact on HAP calculations.
Repeat Finding: No
Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords.
Views of responsible officials: There is no disagreement with the audit finding.