Finding Text
2023-002 Tenant Files: Eligibility
Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871)
Type of Finding: Material non-compliance and Material Weakness in Internal Control over Compliance
This is a repeat finding of 2022-002 from September 30, 2022 (Originally reported as finding 2019-001 from September 30, 2019)
Statement of Condition: Out of a total tenant population of approximately 1,142 vouchers, 25 files were selected for testing, and the following errors were discovered.
• 1 tenant file had the following error:
o The utility allowance was miscalculated by $32 (overstatement). The two-bedroom column utility rates were used when the 1-bedroom column utility rates should have been used. Correcting this error would cause which the HAP rent to decrease from $762 to $731.
• 1 tenant file had the following error:
o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period.
• 1 tenant file had the following error:
o The utility allowance was miscalculated by $23 (understatement). The 2022 utility allowance schedule was used when the 2023 utility allowance schedule should have been used. Correcting this error would cause the HAP rent to increase from $494 to $517.
• 1 tenant file had the following error:
o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen.
• 1 tenant file had the following error:
o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period.
• 1 tenant file had the following error:
o The tenant’s asset income was miscalculated. Correcting this error would increase the HAP rent by $4.
• 1 tenant file had the following error:
o The 50058-form reported childcare income support of $6,000, however, the support for the childcare income showed $5,800. Correcting this error had no effect on the HAP rent.
• 1 tenant file had the following error:
o No support for the tenant’s wage income of $23,296 on the 50058 form. Appears to be reported correctly, since the EIV shows an amount that approximates the tenant’s wage income of $23,296. Nonetheless, there needs to be support in the tenant file for the wage income.
o Missing HAP contract.
• 1 tenant file had the following error:
o The utility allowance was miscalculated by $19 (understatement). Correcting this error would cause the HAP rent to increase from $924 to $943.
In addition to the above, we noted the following during our new admissions testing (out of a total of 161 new admissions, 17 files were selected for testing.):
• 1 tenant file had the following error:
o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen.
• 1 tenant file had the following error:
o HAP contract was not executed timely (within 60 days).
• 1 tenant file had the following error:
o The voucher extension date was not documented on the voucher.
• 1 tenant file had the following error:
o The request for tenancy addendum was executed (dated) two days after the voucher extended due date.
o The unit size on the voucher did not agree to the family voucher size on the 50058 and the wrong payment standard was applied to the tenant.
Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as complete and accurate tenant files. In addition, the Authority’s Administrative Plan also requires following proper procedures for determination of HAP and documentation in the tenant files.
Questioned Costs: None.
Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertification, which could result in incorrect total tenant payments for rent and HAP payments to landlords.
Cause: Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. In addition, the Authority experienced some turnover in the HCV department which contributed to these errors.
Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load.
Views of Responsible Officials of the Auditee: The Authority concurs with this finding. The Authority has an established review, oversight and training process for all of its staff and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed.