AUDIT REPORT
HUD Low-Rent and Section 8 Housing Choice
Voucher Programs
Housing Authority of the City of Greeley and Weld County
Housing Authority, Greeley, Colorado
Tenant Selection and Continued Occupancy Activities
2004-DE-1003
June 22, 2004
U.S. Department of Housing and Urban Development
Regional Inspector General for Audit
1670 Broadway 24TH Floor
Denver, Colorado 80202-4825
Issue Date
June 22, 2004
Audit Case Number
2004-DE-1003
TO: Linda J. Camblin, Director, Office of Public Housing, 8APH
FROM: Robert C. Gwin, Regional Inspector General for Audit, 8AGA
SUBJECT: Tenant Selection and Continued Occupancy Activities
HUD Low-Rent Public Housing and Section 8 Housing Choice Voucher Programs
Housing Authority of the City of Greeley and Weld County Housing Authority
Greeley, Colorado
We have completed an audit of the Low-Rent Public Housing and Section 8 Housing Choice
Voucher Programs for the Housing Authority of the City of Greeley and the Weld County Housing
Authority respectively. Our review focused on tenant selection and continued occupancy activities
based on information we received concerning allegations of improprieties in these areas. The
Housing Authority of the City of Greeley through a consortium agreement with HUD administers
these program activities for both housing authorities. The objective of our review was to determine
whether the housing authorities were conducting their tenant selection and continued occupancy
activities for the two HUD programs in conformity with HUD requirements and their own adopted
policies and procedures.
We reviewed tenant occupancy activities for 20 current and former tenants of the Greeley
Housing Authority Low-Rent Public Housing Program. We also reviewed tenant occupancy
activities for 10 participants each for both the Greeley and the Weld County Housing
Authorities’ Section 8 Housing Choice Voucher Programs. Our review resulted in two findings
along with issues needing further study and consideration
In accordance with HUD Handbook 2000.06, REV-3, within 60 days please provide us, for each
recommendation without a management decision, a status report on: (1) the corrective action
taken; (2) the proposed corrective action and the date to be completed; or (3) why action is
considered unnecessary. Additional status reports are required at 90 days and 120 days after
report issuance for any recommendation without a management decision. Also, please furnish us
copies of any correspondence or directives issued because of the audit.
Management Memorandum
We appreciate the courtesies and assistance extended by the management and staff of both the
Greeley and Weld County Housing Authorities, and the HUD Region 8 Office of Public Housing.
Should you or your staff have any questions, please contact Ernest Kite, Assistant Regional
Inspector General for Audit, at (303) 672-5452.
2004-DE-1003 ii
Executive Summary
We have completed an audit of the Low-Rent Public Housing and Section 8 Housing
Choice Voucher Programs for the Housing Authority of the City of Greeley (GHA) and the
Weld County Housing Authority (WCHA). Our review focused on tenant selection and
continued occupancy activities based on information we received concerning allegations of
improprieties in these areas. The Greeley Housing Authority through a consortium
agreement with HUD administers these program activities for both Housing Authorities.
The objective of our review was to determine whether the Housing Authorities tenant
selection and continued occupancy activities were administered in conformity with HUD
requirements and their own adopted policies and procedures.
Our audit disclosed the need to improve the administration of the Housing Authorities’
tenant selection and continued occupancy activities. Operating procedures did not ensure
that only eligible tenants were being assisted under the HUD programs and that tenants
were paying or receiving the proper assistance amounts. Specifically, our review disclosed
that management controls over the tenant admissions and continued occupancy
requirements were not sufficient to ensure that the applicable Housing Authority properly:
• Determined applicant eligibility and rent/assistance payments;
• Implemented the GHA Income Disregard Program;
• Implemented the GHA Low-Rent applicant waiting list procedures;
• Administered tenant repayment agreements;
• Established/collected security deposits from GHA Low-Rent Program tenants; and
• Determined the WCHA monthly Section 8 administrative fees.
During our review, several areas relating to the accounting for tenant service charges and
tenant account receivables were identified that need further review and corrective action.
The GHA has an Admissions and Continued Occupancy
Deficient controls over Policy for its Low-Rent Housing Program that identifies
Low-Rent tenant procedures to be followed in determining tenant eligibility,
admissions and continued prorating rent, administering the GHA Income Disregard
occupancy activities Program, waiting list procedures, administration of
repayment agreements, and the collection of security
deposits. Tenant eligibility deals with the tenant
identification and documentation of program eligibility by
having the necessary Social Security Cards and citizen or
resident immigration status support. We found information
was not properly documented or supported to show that
GHA Low-Rent tenants were eligible for assisted housing
iii 2004-DE-1003
Executive Summary
or the amount of rental charges were correct. Second,
tenants participating in the GHA Income Disregard
Program were being undercharged their housing rent.
Third, the GHA Low-Rent tenant waiting lists were not
being correctly maintained with some tenant applicants
being provided housing that did not meet the Housing
Authority’s tenant selection criteria. Fourth, the
administration of tenant repayment agreements was not
consistently applied and failed to follow the Housing
Authority’s established procedures. Last, the Housing
Authority’s collection of tenant security deposits was not
consistently applied and was contrary to its adopted tenant
admission procedures. As a result, GHA provided Low-
Rent public housing assistance to ineligible applicants.
Additionally, tenants were not charged the correct rent
amounts and related security deposits. Also, deviation
from the Authority’s established occupancy procedures
could be construed as showing favoritism for certain
tenants.
The GHA and WCHA have an Administrative Plan for
Inadequate administration administering their Section 8 Housing Choice Voucher
of Section 8 Housing Program that identifies procedures to be followed in
Choice Voucher Program determining tenant eligibility, prorating assistance amounts
Occupancy and related and administering repayment agreements. However, we
activities found that the Housing Authorities were not properly
determining and documenting that tenant family members
were eligible citizen or immigrants before Section 8
assistance was provided, and in some cases the amount of
financial assistance provided was incorrectly calculated. In
fact, we identified three families receiving assistance that
did not meet eligibility requirements. We also found that
GHA was not administering its tenant repayment
agreements in a consistent manner and within the
provisions of its Administrative Plan. Last, the WCHA
was not properly determining and/or documenting the
Section 8 administrative fee charged HUD.
Our review showed that Housing Boards of Commissioners
Recommendations policies were not followed or enforced. This occurred
because appropriate management oversight and control
procedures have not been established to ensure compliance
with HUD requirements and the authorities own policies
and procedures. The majority of the functions connected
with the administration of the Low-Rent Housing and the
Section 8 Housing Choice Voucher Programs were vested
2004-DE-1003 iv
Executive Summary
in one individual for each Housing Authority. Without any
oversight and monitoring system in place, the Housing
Authorities have limited assurance that the requirements for
the two HUD programs were being properly and uniformly
implemented. We recommend HUD require the Housing
Authorities to establish the necessary management controls
over its operations to ensure it functions in accordance with
HUD requirements and within the Housing Authorities’
adopted policies. Specific recommendations are provided
with each finding.
Finding outlines were provided to the Housing Authorities
Auditee Comments during the course of the audit. On April 30, 2004, the
Housing Authorities received a copy of the draft audit
report for comment. We received the Housing Authorities’
response on June 4, 2004.
We have included pertinent comments of the Housing
Authorities’ response in the Findings section of this report.
The Housing Authorities’ narrative response is provided as
Appendix B. Supporting documentation contained in the
Housing Authorities’ response was too voluminous to
include in the audit report. These documents were
provided to the HUD Region 8 Office of Public Housing
under separate cover.
v 2004-DE-1003
Executive Summary
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2004-DE-1003 vi
Table of Contents
Management Memorandum ...................................................................... i
Executive Summary ................................................................................ iii
Introduction .............................................................................................. 1
Findings
1. Controls Over Low-Rent Housing Occupancy Activities Need.……..5
To Be Improved
2. Controls Over Section 8 Housing Choice Voucher Program.……….19
Occupancy and Related Activities Need To Be Improved
Management Controls ............................................................................. 29
Follow Up on Prior Audits...................................................................... 31
Issues Needing Further Study and Consideration ................................... 33
Appendices
A. Schedule of Questioned Costs........................................................ 35
B. Auditee Comments......................................................................... 37
C. Distribution .................................................................................... 47
vii 2004-DE-1003
Table of Contents
Abbreviations
HUD U.S. Department of Housing and Urban Development
CFR Code of Federal Regulations
GHA Greeley Housing Authority
WCHA Weld County Housing Authority
2004-DE-1003 viii
Introduction
The Greeley Housing Authority (GHA) and Weld County Housing Authority (WCHA)
have separate contracts with HUD to provide housing assistance services in the City of
Greeley, Colorado and Weld County, Colorado. The GHA started administering the
WCHA housing assistance programs under a contract that was signed in January 1999. In
2001, the two Housing Authorities formed what HUD terms a consortium with GHA
assigned responsibility for administering both housing authorities’ programs. This
relationship also allows for some consolidation of planning and reporting documents. The
same staff administers both Authorities’ housing assistance programs. GHA and WCHA
are tasked to provide safe, decent, and sanitary affordable housing to families and
individuals making between 0 and 80 percent of the median income.
GHA operates a Low-Rent Public Housing Program and a Section 8 Housing Choice
Voucher Program under contract with HUD. The GHA operates 86 low rent public
housing units. These consist of 80 apartments and six single-family houses. The GHA
Section 8 Housing Choice Voucher Program is authorized to provide assistance to 444
families. The GHA also owns a house that is not connected with the Federal government.
In addition, the GHA, under contract with High Plains Housing Development, manages the
following properties: (1) Stagecoach Garden Apartments; (2) La Casa Rosa Apartments;
and (3) Dacono Senior Apartments. These units were financed using Federal Tax Credits.
The WCHA operates a Section 8 Housing Choice Voucher Program under contract with
HUD. The WCHA Section 8 Housing Choice Voucher Program is authorized to provide
assistance to 426 families. In addition, the WCHA, under contract with the State of
Colorado Division of Housing, operates the following programs: (1) Single Family
Rehabilitation Program; (2) Rental Rehabilitation Program: and (3) Emergency
Rehabilitation Program.
The overall objective of our review was to determine
Audit Objectives whether the Greeley and Weld County Housing Authorities
were administering the Low-Rent Public Housing and/or
Section 8 Housing Choice Voucher Programs in
compliance with HUD requirements and their own adopted
policies and procedures.
We tested a non-representative sample of GHA and WCHA
Audit Scope and tenant documents and other records to obtain an
Methodology understanding of the Housing Authorities’ policies and
procedures. We supplemented the non-representative
sample testing of available records with Housing Authority
staff interviews, and HUD Region 8 Office of Public
Housing staff interviews to identify the nature and possible
extent of management control weaknesses.
1 2004-DE-1003
Introduction
Specifically, we reviewed tenant selection and continued
occupancy activities under the HUD Low-Rent Public
Housing and Section 8 Housing Choice Voucher Programs
based upon allegations presented to us concerning the
administration of these program activities. To address
these allegations, we focused our review on determining
whether the two Housing Authorities were conducting their
tenant selection and continued occupancy activities for the
two HUD programs in conformity with HUD requirements
and their own adopted policies and procedures to determine
whether they:
• Followed occupancy policies and procedures;
• Effectively used collection policies and procedures to
maintain control over tenant accounts receivable;
• Properly computed rental assistance amounts;
• Properly charged tenants for services rendered; and
• Maintained public housing units in good repair, order,
and condition.
In conducting the audit, we:
• Reviewed records and files maintained by the HUD
Region 8 Office of Public Housing for both the GHA
and WCHA;
• Interviewed Greeley and Weld County Housing
Authorities officials and employees;
• Toured low-rent public housing units managed by the
GHA;
• Interviewed HUD Region 8 Office of Public Housing
officials and employees;
• Reviewed GHA and WCHA management systems,
records, and files; and
• Reviewed applicable Federal and Housing Authority
policies and procedures to gain an understanding of
their requirements.
2004-DE-1003 2
Introduction
The audit of the two Housing Authorities’ tenant selection
and continued occupancy activities covered the period
between November 1, 2000 and July 31, 2003. Our on-site
review was conducted between August 2003 and March
2004.
We conducted the audit in accordance with generally
accepted government auditing standards.
3 2004-DE-1003
Introduction
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2004-DE-1003 4
Finding 1
Controls Over Low-Rent Housing Occupancy
Activities Need To Be Improved
The Greeley Housing Authority (GHA) needs to improve its controls over the Low-Rent
Housing Program tenant admissions and continued occupancy activities to ensure that
HUD and the authority’s occupancy requirements are being met and being uniformly and
consistently applied. Our review identified five areas where the requirements were not
being properly followed.
The first area dealt with the tenant identification and documentation of program eligibility
by having the necessary Social Security Cards and citizen or resident immigration status
support. Information was not properly documented or supported to show that the Low-
Rent tenants were eligible for assisted housing or the amount of rental charges were
correct. Second, tenants participating in the Income Disregard Program were being
undercharged their housing rent. Third, Low-Rent families were assigned housing units
that did not meet the tenant selection and waiting list requirements. Fourth, the
administration of the tenant repayment agreements was being inconsistently applied and
failed to follow the Housing Authority’s established procedures. Last, the Housing
Authority’s charging and collection of tenant security deposits were being inconsistently
applied and contrary to its adopted tenant admission procedures.
The result is tenants were admitted to GHA’s Low-Rent housing units that were not
eligible or were not being charged the correct housing rent and related security deposit.
In reference to the allegation that addressed waiting list problems, one family was assigned
to a public housing unit without being on the waiting list and no application on file, while
another family received public housing assistance even though their name should have
been removed from the waiting list.
TENANT ELIGIBILITY AND RENT PRORATION
Federal regulations and
Housing Authority Title 24 of the Code of Federal Regulations, Part 5, along
guidance require with provisions of the GHA Admissions and Continued
adequate documentation Occupancy Policy, requires each assisted applicant to
of tenant eligibility submit their complete and accurate Social Security Number
for all household members who are at least six years of age.
For those family members who are under six years of age,
the family must submit documentation the individual is a
family member. In addition, each family member is to
submit a written declaration declaring the individual family
member is a United States citizen or a non-citizen with
eligible immigration status. The Regulations also provide
the Housing Authority with specific instructions to be
followed if the family member fails to submit the required
5 2004-DE-1003
Finding 1
evidence of eligible immigration status. Furthermore, no
assistance is to be provided prior to the verification of
eligibility of at least the individual or one family member.
HUD Handbook 7465.7 requires the Housing Authority to
verify immigration status with the United States
Immigration and Naturalization Service automated system
called Systematic Alien Verification for Entitlements.
However, an individual who is not a United States citizen
or who does not have eligible immigration status is to be
listed on a statement of non-contending family members
signed by the head of household or spouse. If an applicant
or tenant family members fails to sign required declarations
and consent forms or provide documents, as required, they
must be listed as an ineligible member. If the entire family
fails to provide and sign as required, the family may be
denied or terminated for failure to provide required
information.
The purpose of the HUD requirements as supplemented
with the GHA Admission and Continued Occupancy Policy
is to ensure that only eligible families are selected and
participate in the Low-Rent Housing Program and that the
proper rental assistance, or prorated amount, is being
provided.
We selected and reviewed eligibility documentation for 87
family members of 20 current and former tenants of the
GHA Low-Rent Public Housing Program. Our review
disclosed:
• For eighteen family members, no documentation for the
Social Security Numbers could be located.
• For ten family members, the necessary Social Security
Number verification procedure was not followed.
• For seven family members under age six,
documentation supporting their eligibility as a member
of the particular family was not available.
• For eighteen family members, the required declaration
statement identifying their citizenship or eligible
immigration status was not available in their tenant file.
Of the 63 family members who did have a declaration form
in their tenant files, the citizenship or eligible immigration
2004-DE-1003 6
Finding 1
status for six family members was not shown. For three
children family members, an adult family member who was
responsible for them did not sign the declaration form as
required. For the remaining six family members, three
provided a Listing of Non Contending Family Members
and three were placed in the unit prior to the effective date
of the Non Citizen Rule and beyond the three year record
retention requirement.
The GHA is required to prorate the rent on family members
Required proration who do not submit evidence or establish their eligible
procedures not followed citizenship status. Of the 20 current and former tenants
reviewed for eligibility documentation, six tenants had
family members who did not submit evidence or establish
their eligible citizenship status. Five families had one or
more family members without a declaration document.
Our review disclosed that the GHA did not properly prorate
the rent on these families resulting in a rental loss of
$10,089. In addition, there was no declaration document
on any family members for the sixth family. Therefore,
this family was not eligible to participate in the GHA Low-
Rent Public Housing Program.
The result of these deficiencies is that the Housing
Authority has not properly documented its files concerning
the Social Security Number of applicable tenant family
members and the eligible citizenship or immigration status
of tenant members. Without such documentation, the
Housing Authority is unable to demonstrate that its tenants
and individual family members are eligible to participate in
the HUD funded Low-Rent Housing Program.
Furthermore, the tenants may not be paying their correct
rental payment.
INCOME DISREGARD PROGRAM
Income Disregard
Program requirements The GHA developed their Income Disregard Program to
encourage families to become more self-sufficient by
temporarily reducing the amount of rent the tenants are
required to pay over a two year period after finding work
and leaving unemployment. The GHA incorporated the
HUD requirements for the program as contained in Section
960.255, Title 24 of the Code of Federal Regulations into
their Admission and Continued Occupancy Policy. Under
the program, a Low-Rent Housing Program family is
eligible to participate in the program whose annual income
7 2004-DE-1003
Finding 1
increases as a result of employment of a family member
who was unemployed for one or more years previous to
their employment.1 As such, the Housing Authority can
exclude the increase in income of a participant, not the total
income of the participant, in calculating what the tenant’s
rent should be.
We selected and reviewed the files for four tenants who
Required eligibility and were participating in the GHA Income Disregard Program
income adjustment under the GHA Low-Rent Housing Program. Our review
procedures not followed disclosed that all four tenants had a yearly income that
exceeded the established minimum wage limit during the
preceding year when they were considered unemployed,
and none of them were unemployed for one or more years
immediately preceding the increase in income prior to their
new employment. As a result, none of the four tenants
were eligible to participate in the Income Disregard
Program. In addition, we noted that three of the four
tenants had their entire income, not just the amount of
increase, excluded from their rental calculations, thus
causing a rental loss of $7,226 to the GHA.
This situation stems from a misunderstanding on the part of
GHA employees administering the program requirements.
In addition, the Income Disregard Program letter that is
sent to program participants indicates that the entire income
will be excluded from the rent calculation. Program
requirements only permit the increase in income from
employment to be excluded from the calculation.
WAITING LISTS
Waiting Lists need to be
properly established and HUD Regulations in Section 960.206, Title 24 of the Code
uniformly applied of Federal Regulations details the requirements and
provides guidance to authorities in implementing local
preference procedures for the admission of tenants into its
assisted programs. The Greeley Housing Authority has
implemented its Admissions and Continued Occupancy
Program to implement the Federal requirements. Basically,
tenant applicants prepare an application and based upon
preliminary evaluation are placed on a waiting list based
upon bedroom size need. When a tenant’s name reaches
1
Unemployment is defined as a person who has earned, in the twelve months previous to employment, no more than
would be received for 10 hours of work per week for 50 weeks at the established minimum wage. Increased
earnings by a family member during participation in a job training program or receiving assistance under any state
program for temporary assistance for needy families would qualify for the disallowance.
2004-DE-1003 8
Finding 1
the top of the waiting list, the tenant is processed for the
next available unit. The process is to grant each applicant
equal opportunity to be selected for available housing.
We selected and reviewed four families on the GHA Low-
Improper implementation Rent Public Housing Program waiting lists to determine if
of waiting list procedures the allegation that addressed waiting list problems was an
isolated incident or if it was indicative of a larger problem.
Our review showed the following:
• One individual received public housing assistance with
no application on file and not being on any public
housing waiting list and one applicant is receiving
public housing assistance even though their name
should have been removed from the waiting list for not
providing requested information specified by the GHA.
• One family was placed on the waiting list based upon
an incorrect application date and one family was
dropped from the waiting list for a six-month period for
an unknown reason.
These results indicate the GHA is not following their
procedures related to the placement, denial, and selection of
applicants from the Low-Rent public housing waiting lists.
Applicants were not being placed and selected from the
low-rent public housing waiting lists as required.
Therefore, the GHA’s selection process is failing to meet
HUD requirements and its own admission policy. The
result is ineligible families are residing in GHA public
housing units.
ADMINISTRATION OF REPAYMENT
Housing Authority AGREEMENTS
policies address
repayment agreements Chapter Fifteen of the GHA Admission and Continued
Occupancy Policy addresses delinquent payments that are
due the authority. The GHA developed their repayment
agreement procedures to help them account for tenants who
owe monies for various charges (i.e.: back rent, charges for
repairs to the unit beyond normal wear and tear caused by
the tenant, etc.). These procedures are to apply equally to
all tenants including any authority employees who
currently have or previously had a repayment agreement.
9 2004-DE-1003
Finding 1
There are some circumstances in which the Housing
Authority may not enter into a repayment agreement. One
of these circumstances is if the family already has a
repayment agreement in place. In addition, if a family
already has a repayment agreement in place and incurs an
additional debt to the PHA, the PHA is not to enter into
more than one repayment agreement at a time with the
same family.
The Repayment Agreement Form utilized by the GHA
states that the resident understands that if timely payments
are not made, their contract is null and void, the remaining
amount delinquent becomes due in full, and the authority
will begin legal proceedings to terminate the lease.
We selected and reviewed four tenants who had a
Required repayment repayment agreement with the GHA. Our review showed
agreement procedures not the following:
followed
• Two tenants were making the required monthly
payments.
• Two tenants were not making the required monthly
payments. Under provisions of the repayment
agreement, these two tenants should have had their
repayment agreement revoked, the required delinquent
amount should have been paid in full, and the lease
terminated.
These results indicate the GHA is not following their
procedures related to the administration of repayment
agreements with tenants and in conformity the Housing
Authority’s policy and procedures. Some tenants are not
having the terms of their repayment agreements enforced as
required. The impact is some tenants repayment
agreements were not enforced allowing them to continue to
reside in the public housing unit while other eligible
families continue to wait for public housing assistance.
SECURITY DEPOSITS
Federal regulations and
Housing Authority Section 966.4 of Title 24 of the Code of Federal
policies allow for the Regulations provides an authority with the option to
collection of security establish and collect a security deposit from tenants
deposits receiving public housing assistance. It also establishes
limits on the amount of the security deposit. Chapter Nine
2004-DE-1003 10
Finding 1
of the GHA Admission and Continued Occupancy Policy
indicates new tenants must pay a security deposit to the
Housing Authority at the time of admission. The amount
of the security deposit required is specified in the tenant’s
lease.
The GHA utilizes security deposits to help defray such
costs as unpaid rent, damages listed on the Move-Out
Inspection Report that exceed normal wear and tear, and
other charges under the lease when the tenant leaves the
unit. The GHA established procedures in their Admission
and Continued Occupancy Policy to address these
conditions. These procedures would apply equally to all
tenants.
We examined the payment of security deposits on six of the
Improper collection and 20 tenants in the GHA Low-Rent Public Housing Program
administration of security that were part of our review. We found that two tenants
deposits were assigned to their low-rent public housing unit without
paying their required security deposit prior to admission.
The lease agreement for one of these two tenants specified
a security deposit of $200 while the lease agreement for the
other tenant specified a security deposit of $300. The lease
agreements for the other four tenants stipulate they agreed
to pay a $300 security deposit. However, two of these
tenants only paid $200 towards their security deposits while
the other two tenants only paid $100 towards their security
deposits. As of August 20, 2003, these six tenants owe the
Housing Authority $1,100 in security deposits.
These results indicate the GHA is not following their
procedures related to the payment of security deposits by
their tenants. Some tenants are not being required to pay
the established amount of their security deposit at the time
of admission. Therefore, funds are not available to defray
such costs as unpaid rent and repairs for damages beyond
normal wear and tear that are caused by these tenant.
Our office received a number of allegations related to
Management Controls occupancy issues of the GHA. Results of our review in the
lacking areas discussed above support a number of those
allegations. We found that approved Housing Board of
Commissioner policies were not being properly and
consistently enforced. This has occurred because the GHA,
in carrying out its various tenant policies, has not
established sufficient monitoring and oversight procedures
11 2004-DE-1003
Finding 1
to ensure required policies, HUD guidance, and HUD
regulations are implemented. These policies, HUD
guidance, and HUD regulations apply equally to all tenants.
However, GHA program recipients have not received
uniform and consistent benefits.
While some of the deficiencies discussed above occurred
due to a possible lack of documentation or from a
misunderstanding on the part of GHA officials
implementing the HUD and Housing Authority
requirements, we found that the Housing Authority lacked
sufficient procedures that ensured that the established
requirements were being followed. Primarily, most
functions relating to the admission and continued
occupancy of the Housing Authority tenants, including the
collection of security deposits and assessments of rents,
was vested with one individual.
Overall, the Greeley Housing Authority responded that they
Auditee Comments diligently endeavor to ensure all participants are qualified
to receive assistance prior to being placed on the program,
and annually at recertification. They further explain that
any deficiencies noted in the OIG audit report are not of a
detrimental nature and result from newly implemented
policies, ongoing training, continual updating of computer
systems, and an attempt to cross train staff. The Greeley
Housing Authority response affirms that it is abiding with
all of HUD’s regulations.
The Housing Authorities provided the following comments
for each deficiency noted in the finding:
Tenant Eligibility and Rent Proration: The Greeley
Housing Authority asserts that it is not allowing ineligible
non-citizens into any Housing Program. The Greeley
Housing Authority further responds on the process used to
receive applications and process them before a family
enters into a Housing Program. However, the Greeley
Housing Authority does state all files have been reviewed
and any missing information, documentation and/or
incomplete eligibility forms are being obtained from the
households. Lastly, the Greeley Housing Authority states it
will take action to prorate the rents of any undocumented
residents.
2004-DE-1003 12
Finding 1
Income Disregard Program: The Greeley Housing
Authority asserts that all tenants participating in their
Income Disregard Program did qualify. The Greeley
Housing Authority further asserts that the error due to
inaccurate application and calculations represents a
$3,682.59 loss in rent, not the quoted $7,226. The Greeley
Housing Authority identifies the process they use to
calculate the rent of their program participants along with
specifying the maximum time frame per adult household
member of program availability. Finally, the Greeley
Housing Authority states its staff has been retrained and
tools purchased in an effort to ensure compliance.
Waiting Lists: The Greeley Housing Authority states one
of the individuals being referred to in the finding is a staff
member who was placed on site as an on-site manager and
they agree that the waiting list related to this transaction
was bypassed. The Greeley Housing Authority asserts that
the person who was absent for six months could be the
result of a few different scenarios but since the information
is no longer available, the Housing Authority cannot
respond to this deficiency. The Greeley Housing Authority
provides an explanation of their waiting list process. In
addition, the Greeley Housing Authority states their staff
has been directed to make all documentation to files in
writing to be place in the files permanently. Notations are
to be made on the printed waiting lists and in the computer.
Administration of Repayment Agreements: The Greeley
Housing Authority asserts that while their Admissions and
Continued Occupancy Policy states they will not enter into
a repayment agreement if one is in place, it does not say
they may not alter the original agreement, cancel it and
issue a new one. The Greeley Housing Authority further
asserts that all repayment agreements are enforced and
collected on. The Greeley Housing Authority provides an
explanation of their repayment agreement issuance and
approval procedures. The Greeley Housing Authority
states they will review all repayment agreements in place
and bring them current either through adverse action to the
tenant or through modification of the current agreement.
Security Deposits: The Greeley Housing Authority states
to facilitate quicker recertification and lease up
appointments the current amount of the security deposit
was typed into Part II of the lease. Changing of staff, board
13 2004-DE-1003
Finding 1
members, and the updating of the lease annually had led to
an oversight as the security deposit changed from $100 to
$200 and finally to $300. The Greeley Housing Authority
asserts they face a legal challenge if they should attempt to
retroactively change and collect security deposit money
based upon new policies from currently leased tenants.
Finally, the Greeley Housing Authority states they have
changed Part II of the lease to allow their Public Housing
Manager to accurately write the actual security deposit paid
in the lease for recertification and the current going rate of
security deposits for newly leasing tenants.
OIG Evaluation of Tenant Eligibility and Rent Proration: The Greeley
Auditee Comments Housing Authority stated they are not allowing ineligible
non-citizens in any of their programs. We disagree as
documentation examined during our review showed that
some family members did not meet the specific tenant
eligibility requirements. However, we agree with the
actions taken by the Greeley Housing Authority through
their review of all of their Low-Rent Public Housing
Tenant Files to identify incomplete and missing declaration
documents, requesting copies of missing Social Security
Cards, identifying incomplete or missing tenant
identification information, updating lease documentation,
identifying miscellaneous documentation needed, and
prorating the rent on any tenants who do not provide the
necessary and requested information. These actions should
help correct the deficiencies noted in the finding related to
tenant eligibility and rent proration.
Income Disregard Program: We disagree with the Greeley
Housing Authority that those tenants participating in their
Income Disregard Program met HUD qualification
requirements and that only $3,683 in loss rental revenues is
due instead of the $7,226 identified by us. The Authority
provided supporting documentation on four tenants who are
currently participating in their Income Disregard Program,
two of whom were not participating in the Program during
the time of our review and are not addressed in the finding.
For the two who were participating in the Program during
our audit period, the documentation provided did not show
the tenants met the earned income disallowance
requirements. Therefore, we still conclude that the four
2004-DE-1003 14
Finding 1
Program participants discussed in the finding did not meet
the Program requirements and were ineligible.
Waiting Lists: We do not disagree with the Greeley
Housing Authority's assertion that all waiting lists prior to
December 2000 were either destroyed or packaged for
disposal. We utilized waiting lists from December 2000
forward to validate the Greeley Housing Authority's
implementation of their waiting list procedures. Therefore,
any waiting list records prior to December 2000 that were
either destroyed or packaged for disposal did not impact
our review of the Authority’s waiting list procedures. The
Greeley Housing Authority indicates that they lost all of
their "notes" related to waiting list issues on individual
applicants during a 2003 computer update. In order to
correct this problem and those issues identified by us, the
Greeley Housing Authority has directed their staff to place
a copy of the "notes" related to each applicant’s
position/placement in the printed waiting lists along with
being placed in their computer database. These actions
taken by the Greeley Housing Authority should help correct
the waiting list processing deficiencies noted in the finding.
Administration of Repayment Agreements: The Greeley
Housing Authority asserts that all repayment agreements
are enforced. This statement differs from the facts
presented in the finding that the Authority was not
uniformly implementing the terms of the repayment
agreement for all tenants who possessed one. Even so, the
Greeley Housing Authority indicates they will review all
repayment agreements in place and bring them current
either through adverse action to the tenant or through
modification to the existing repayment agreement. These
actions should help the Authority correct the deficiencies
noted in the finding.
Security Deposits: While the Authority is addressing
changes to its tenant lease security deposit requirements
and procedures, no comments are made to address the items
discussed in the finding. These include tenants not paying
the full amount of the security deposit specified in their
lease or tenants not paying their security deposit before
being admitted to an Authority dwelling unit.
15 2004-DE-1003
Finding 1
Recommendations We recommend the HUD Region 8 Office of Public
Housing:
1A. Require the GHA to implement sufficient
administrative controls and procedures over its
Low-Rent tenant admission and continued
occupancy program activities to ensure that the
HUD and GHA requirements are being correctly
and consistently implemented. This will include:
• Required Social Security Cards and/or related
documents are properly obtained for all family
members and documented.
• All necessary citizen eligibility forms are
obtained for all family members and properly
documented. This would ensure the appropriate
tenant rents are being correctly calculated.
• Rents for tenants participating in the Income
Disregard Program are being properly
calculated and charged to the tenants.
• Waiting lists are being properly established and
maintained and that tenants are being placed in
housing in conformity with the GHA adopted
Admissions and Continued Occupancy Policy.
• Tenant repayment agreements are being
properly implemented and consistently enforced
in conformity with the GHA adopted
procedures.
• Security deposits are being uniformly and
consistently charged to incoming tenants in
accordance with the GHA Admissions and
Continued Occupancy Policy.
1B. Require the GHA to determine that all of its current
Low-Rent Housing Program tenants have provided
all of the necessary eligible citizen or resident
immigration status documentation and that the
tenant rent is correctly calculated and charged to the
tenant accordingly. Any ineligible tenant families
2004-DE-1003 16
Finding 1
should be processed in accordance with the GHA’s
Admission and Continued Occupancy Policy.
1C. Require the GHA to reevaluate the rent being
charged to its Low-Rent tenant families
participating in the Income Disregard Program and
make any necessary rent adjustments.
1D. Require the GHA to make restitution of $7,226 in
undercharged rent from the Income Disregard
Program participants to the GHA operating fund.
Restitution to the GHA operating fund may be made
from other Non Federal sources.
1E. Require the GHA to secure payment of $1,100 in
delinquent security deposits from the six tenants
that were part of the 20 tenant sample. For the
remaining 66 tenants, require the GHA to collect
any differences between the security deposit
specified in the lease agreement with that paid by
the tenant.
17 2004-DE-1003
Finding 1
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2004-DE-1003 18
Finding 2
Controls Over Section 8 Housing Choice
Voucher Program Occupancy And Related
Activities Need To Be Improved
Both the Greeley Housing Authority (GHA) and the Weld County Housing Authority
(WCHA) can improve its administration of their occupancy and related activities of the
Section 8 Housing Choice Voucher Program. This is needed to ensure that the Housing
Authorities are implementing the Section 8 Housing Choice Voucher Program in
conformity with HUD requirements and their Administrative Plans and that rental
assistance to program tenants are uniformly and consistently applied.
We found that the Housing Authorities were not properly determining and documenting
that tenant family members were eligible citizen or immigrants before they were receiving
Section 8 rental assistance and in some cases the amount of financial assistance was
incorrectly calculated. Three families were identified as receiving rental assistance but the
families did not meet the eligibility requirements. Also, the GHA was not administering its
tenant repayment agreements in a consistent manner and with the provisions of its
Administrative Plan. Last, the WCHA was not properly documenting its program
administrative fee that it was charging HUD.
ELIGIBILITY AND RENTAL ASSISTANCE
Federal regulations and
PRORATION
Housing Authority
guidance require adequate
Title 24 of the Code of Federal Regulations, Part 5, along
documentation of tenant
with the provisions contained in the Administrative Plan for
eligibility
both Greeley and Weld County Housing Authorities
requires each Section 8 assistance program applicant to
submit their complete and accurate Social Security Number
along with those of all household members who are at least
six years of age. In addition, each family member is to
submit a written declaration declaring the individual family
member is a United States citizen or a non-citizen with
eligible immigration status. The Regulations also provide
the Housing Authorities with specific instructions to be
followed if the family member fails to submit required
evidence of eligible immigration status. Furthermore, no
assistance is to be provided prior to the verification of
eligibility of at least one family member. HUD Handbook
7465.7 requires an authority to verify immigration status
with the United States Immigration and Naturalizations
Service automated system called Systematic Alien
Verification for Entitlements. Chapter Seven of the
19 2004-DE-1003
Finding 2
GHA/WCHA Administrative Plan allows an individual
who is not a United States citizen or who does not have
eligible immigration status may elect not to contend their
status. If an applicant or tenant family member fails to sign
required declarations and consent forms or provide
documents, as required, they must be listed as an ineligible
member. If the entire family fails to provide and sign as
required, the family may be denied or terminated for failure
to provide required information.
The purpose of the HUD requirements as supplemented
with the two Housing Authorities’ Administrative Plan is to
ensure that only eligible families are selected and
participate in their Section 8 Housing Choice Voucher
Program and that the proper rental assistance, or prorated
amount, is being provided.
We selected and reviewed eligibility documentation for the
Section 8 Housing Choice Voucher Program relating to 38
family members belonging to 10 GHA tenants and for 22
family members belonging to 10 WCHA tenants. We
noted deficiencies in the eligibility of the family members
for both Housing Authorities. These are summarized
below by Housing Authority:
Greeley Housing Authority
• The Social Security Number for four family members
was not documented in the tenant file with a copy of
their Social Security Card;
• One family member did not have under age six
documentation in the tenant file supporting their
eligibility;
• Three family members of one tenant did not submit the
required declaration form for their citizenship or
eligible immigration status;
• For a three-member family, the head of household did
not have the necessary immigration card supporting the
member’s immigration eligibility while the two other
members did not have their required
citizen/immigration eligibility declaration form signed
by the head of household; and
2004-DE-1003 20
Finding 2
• One tenant was ineligible for rental assistance since all
members of the family did not have the required
citizen/immigration eligibility declaration form in their
file.
Weld County Housing Authority
• Two family members did not have a copy of their
Social Security Card in their tenant file;
• Four family members did not have the required
citizen/immigration eligibility declaration form in their
tenant file; and
• Two tenants were ineligible for rental assistance since
all members of the families did not have the required
citizen/immigration eligibility declaration form in their
files.
In addition, the Housing Authorities are required to prorate
Required proration the assistance on family members who do not submit
procedures not followed evidence or establish their eligible citizenship status. Four
families were reviewed who had one or more family
members without the required citizenship declaration form
in their files. Our review disclosed that the GHA did not
properly prorate the assistance on two tenants resulting in
an assistance loss of $2,449 and the WCHA did not
properly prorate the assistance on two tenants resulting in
an assistance loss of $3,748. In addition, the one GHA
family and the two WCHA families who did not have the
required citizenship declaration forms in their file were not
eligible to participate in the Section 8 Housing Choice
Voucher Program.
These results stemmed from the fact that both Housing
Authorities lacked sufficient procedures to ensure that the
HUD regulations and their own Administrative Plan
requirements were being followed. The impact is the
Housing Authorities are providing rental assistance for
family members who are not supported as being
citizenship/legal immigrant eligible. In addition, three
families are receiving rental assistance that is not supported
as being eligible.
21 2004-DE-1003
Finding 2
ADMINISTRATION OF REPAYMENT
Housing Authority AGREEMENTS
policies address
repayment agreements Chapter Eighteen of the Administrative Plan for the GHA
addresses delinquent payments that are due the Housing
Authority. There are some circumstances in which the
Housing Authority will not enter into more than one
repayment agreement with a family. The Repayment
Agreement Form utilized by the GHA Section 8 Housing
Choice Voucher Program states that when the Repayment
Agreement is in default, all monies are due in full and no
further Repayment Agreements will be made with the same
family. The GHA developed their repayment agreement
procedures to help them account for tenants who owe
delinquent monies for various charges.
We selected all GHA tenants that had a repayment
Required repayment agreement. Two tenants had a repayment agreement under
agreement procedures not the Section 8 Housing Choice Voucher Program and a third
followed tenant should have had a repayment agreement. Of the two
tenants with a repayment agreement, one repayment
agreement was being properly administered while the
second was not. The tenant made 2 of the 8 required
payments on the repayment agreement that should have
been completed by October 2001. The tenant owes GHA
$446 in arrears. The GHA Section 8 Housing Choice
Voucher Program Administrator has reinstated the second
repayment agreement after being notified of the deficiency.
The GHA Section 8 Housing Choice Voucher Program has
incurred a $594 assistance loss for the third tenant who
should have had a repayment agreement but did not.
These results indicate the GHA Section 8 Housing Choice
Voucher Program is not equally implementing their
procedures related to the administration of repayment
agreements on those tenants who possess one. Some
tenants are not having the terms of their repayment
agreements enforced as required.
DETERMINATION OF MONTHLY
Federal regulations ADMINISTRATIVE FEES
authorize the charging of
administrative fees Under the Section 8 Housing Choice Voucher Program, a
housing authority is authorized to charge an administrative
fee primarily for each unit that is being utilized under the
program. Section 982.152 authorizes the payment of an
2004-DE-1003 22
Finding 2
administrative fee for each program unit under a Housing
Assistance Payment contract the first day of the month.
We reviewed the November 2003 administrative fee
Improper charging of charged for eight tenants of the WCHA Section 8 Housing
administrative fees Choice Voucher Program. Our review disclosed that six
tenants who were included in the November 2003
administrative fee were not under a lease as of the first of
November. In addition, four of these tenants were included
in the calculation of prior monthly administrative fees when
they should not have been. The WCHA Section 8 Housing
Choice Voucher Program charged $704.10 in ineligible
administrative fees for these six tenants over the period
August through November 2003.
Tenant Period Amount
A August thru November $187.76
B August thru November 187.76
C September thru November 140.82
D October thru November 93.88
E November 46.94
F November 46.94
TOTAL $704.10
The WCHA makes adjustments to their administrative fees
as errors and/or changes become evident. In addition,
Deficient controls over Housing Authority officials stated that they try to error on
the calculation and the conservative side in charging HUD for administrative
charging of administrative fees. However, the Housing Authority does not document
fees its administrative fee adjustments. Accordingly, without
documentation, the Housing Authority is limited in being
able to determine whether its administrative fees charged
HUD is accurate.
The WCHA needs to establish a formalized system for
calculating the administrative fees charged to HUD. The
system should account for and fully document all
adjustments made.
These areas of deficiencies discussed above point out the
need for the Housing Authorities to improve its
administrative procedures over its Section 8 Housing
Choice Voucher Program to ensure that they are fully
complying with HUD requirements as well as with their
Administrative Plan procedures. We found that the
administration of each Housing Authority’s program was
23 2004-DE-1003
Finding 2
being conducted with most major administrative functions
being carried out by one staff member with no overview or
monitoring of the Section 8 Housing Choice Voucher
Program activities. Without any oversight or monitoring,
the Housing Authorities have limited assurance that its
Section 8 Housing Choice Voucher Program is being
conducted as intended and within the prescribed HUD
requirements.
Auditee Comments The Housing Authorities provided the following comments
for each deficiency noted in the finding:
Eligibility and Rental Assistance Proration: The Greeley
and Weld County Housing Authorities assert that it is not
allowing ineligible non-citizens into any Housing Program.
The Greeley and Weld County Housing Authorities further
respond on the process used to receive applications and
process them before a family receives rental assistance.
However, the Greeley and Weld County Housing
Authorities do state that they are checking all files for
applicable documentation as part of the recertification
process. Finally, the Greeley and Weld County Housing
Authorities state it will take action to prorate the rental
assistance of any undocumented residents.
Administration of Repayment Agreements: The Greeley
Housing Authority asserts that while their Administrative
Plan states they will not enter into a repayment agreement
if one is in place, it does not say they may not alter the
original agreement, cancel it and issue a new agreement.
The Greeley Housing Authority further asserts that all
repayment agreements are enforced and collected on. The
Greeley Housing Authority provided an explanation of
their repayment agreement procedures. The Greeley
Housing Authority states they will review all in place
repayment agreements and bring them current either
through adverse action to the tenant or through
modification of the current agreement and ensure the date
has been input into the computer software system.
Determination of Monthly Administrative Fees: The Weld
County Housing Authority states they operate in good faith
regarding the administrative fee collection. They are not
able to make automatic adjustments to calculations in their
computer system because it is a real time system designed
2004-DE-1003 24
Finding 2
to prohibit staff from going back and altering records in an
attempt to defraud the program. The Weld County Housing
Authority asserts there were 16 tenants under contract on
the first of the month but they had not been placed into the
computer system. As a result, $751.04 in administrative
fees was not collected. The Weld County Housing
Authority further asserts that the $751.04 in uncollected
administrative fees offsets the $704.10 in overcharged
administrative fees and they do not intend to collect the
difference. Finally, the Weld County Housing Authority
stated how they will revise their operating procedures to
ensure they properly account for administrative fees.
OIG Evaluation of Eligibility and Rental Assistance Proration: The Greeley
Auditee Comments and Weld County Housing Authorities have stated they are
not allowing ineligible non-citizens in any of their
programs. We disagree as documentation examined during
our review showed that some family members did not meet
the specific tenant eligibility requirements. However, we
agree with the actions taken by the Greeley and Weld
County Housing Authorities through their review of all of
their Section 8 Housing Choice Voucher Program Tenant
Files during the recertification process to identify
incomplete and missing declaration documents, other
documentation needed, and prorating the rental assistance
on any tenants who do not provide the necessary and
requested information. These actions taken by the Greeley
and Weld County Housing Authorities should help correct
the deficiencies noted in the finding related to eligibility
and rental assistance proration.
Administration of Repayment Agreements: The Greeley
Housing Authority asserts that all repayment agreements
are enforced. This statement differs from the facts
presented in the finding that the Authority was not
uniformly implementing the terms of the repayment
agreement for all tenants who possessed one. Even so, the
Greeley Housing Authority indicates they will review all
repayment agreements in place and bring them current
either through adverse action to the tenant or through
modification to the existing repayment agreement. These
actions should help the Authority correct the deficiencies
noted in the finding.
25 2004-DE-1003
Finding 2
Determination of Monthly Administrative Fees: The Weld
County Housing Authority did not provide any supporting
documentation about their claim that we did not take into
account 16 tenants who were under contract on the first of
the month but had not been placed into the computer
system. These 16 tenants should have been part of the
administrative fee but they were left out resulting in
$751.04 in uncollected administrative fees. Without
supporting documentation, we are not able to validate their
claim. However, the Weld County Housing Authority
Section 8 Administrator is to begin maintaining a monthly
computer generated administrative fee calculation sheet,
manually write the name of the tenant who was added or
deleted from the program for which an administrative fee is
due, and provide a copy to the accountant for manual
corrections in the accounting records at the end of the
month. These actions should help eliminate problems
associated with the charging of administrative fees in the
future.
Recommendations We recommend the HUD Region 8 Office of Public
Housing:
2A. Require the GHA and the WCHA to implement
sufficient administrative controls and procedures
over its Section 8 Housing Choice Voucher
Programs admission and continued occupancy
activities to ensure that the HUD and Housing
Authority Administrative Plan requirements are
being met. These would ensure that:
• Required Social Security Cards and/or related
eligibility documents are properly obtained for
all family members and documented; and
• All necessary citizen eligibility forms are
obtained for all family members and properly
documented. These would ensure the
appropriate tenant rents are correctly calculated
and adjusted accordingly and those determined
to be ineligible program tenants to be processed
in accordance with the Housing Authority
Administrative Plans.
2004-DE-1003 26
Finding 2
For the GHA, it would ensure that its tenant
repayment agreements are uniformly and consistent
implemented and carried out in accordance with its
Administrative Plan.
For the WCHA, it would ensure that the Section 8
Housing Choice Voucher Program administrative
fees are properly calculated and documented on a
monthly basis. In addition, the Housing Authority
should recalculate the 2003 administrative fees for
its program and make any appropriate adjustments
to HUD. The recalculation does not need to include
all tenants in November, or the six tenants already
identified for August thru October.
2B. Require the GHA to secure payment of $446 in
arrears from the repayment agreement that was not
enforced, and $594 for the tenant who should have
had a repayment agreement.
2C. Require the WCHA to make $704.10 in adjustments
to HUD for the ineligible administrative fees
charged to HUD for the six tenants between August
and November 2003.
27 2004-DE-1003
Finding 2
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2004-DE-1003 28
Management Controls
In planning and performing our audit, we obtained an understanding of the management controls
that were relevant to our audit. Management is responsible for establishing effective
management controls. Management controls, include the plan of organization, methods and
procedures adopted by management to ensure that its goals are met. Management controls
include the processes for planning, organizing, directing, and controlling program operations.
They include the systems for measuring, reporting, and monitoring program performance.
Management Controls We determined the following management controls were
Assessed relevant to our audit objectives:
• Tenant Accounts Receivable System;
• Occupancy System;
• Low-Rent Unit Condition/Utilization, and;
• Section 8 Housing Choice Voucher Program
Administrative Sytem.
Assessment Procedures We used the following audit procedures to evaluate the
management controls:
• Reviewed records and files maintained by the HUD
Region 8 Office of Public Housing for both the
GHA and WCHA;
• Interviewed Greeley and Weld County Housing
Authorities officials and employees;
• Toured low-rent public housing units managed by
the GHA;
• Interviewed HUD Region 8 Office of Public
Housing officials and employees;
• Reviewed GHA and WCHA management systems,
records, and files; and
• Reviewed applicable Federal and Housing
Authority policies and procedures to gain an
understanding of their requirements.
It is a significant weakness if management controls do not
provide reasonable assurance that the process for planning,
29 2004-DE-1003
Management Controls
organizing, directing, and controlling program operations
will meet an organization's objectives.
Significant Weaknesses Our review indicates the two Housing Authorities lacked
the management controls necessary over the administration
of their admissions and continued occupancy programs to
ensure that they:
• Properly determine applicant eligibility and rent
proration;
• Properly implement the GHA Income Disregard
Program;
• Properly implement the Low-Rent Housing
Program waiting list procedures;
• Properly administer repayment agreements;
• Properly establish and collect security deposits from
GHA Low-Rent Program tenants; and
• Correctly determine WCHA monthly administrative
fees.
2004-DE-1003 30
Follow Up on Prior Audits
This is the first time that the Greeley Housing Authority and Weld County Housing Authority
have been reviewed by the HUD Region 8 Office of Inspector General for Audit. However, the
HUD Region 8 Office of Public Housing conducted a monitoring review of both Housing
Authorities. The HUD Region 8 Office of Public Housing issued their Management Review
Report on December 10, 2001 and it contained five findings with related recommended
corrective actions. The Management Review Report also contained six observations. The five
findings deal with:
1. The Family Self-Sufficiency Program;
2. Tenant Files;
3. Units failed Housing Quality Standards Inspections;
4. Resident on the Housing Board of Commissioners; and
5. Waiting Lists.
31 2004-DE-1003
Follow Up on Prior Audits
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2004-DE-1003 32
Issues Needing Further Study and Consideration
During our review, several areas relating to the accounting for tenant service charges and tenant
account receivables were identified that need further review and corrective action. These two
areas are discussed below:
Tenant Service Charges: The Greeley Housing Authority (GHA) is not always charging its
Low-Rent housing tenants for services rendered. During our review of work orders for
damages caused by the tenant beyond normal wear and tear on four dwelling units, these
deficiencies were noted:
• In one instance, no work order was established for the maintenance work; and
• In two instances, work order charges were not recorded against the applicable tenant.
We also noted that the Housing Authority is not recording work order charges to the tenant’s
account in a timely manner. Charges for unit repairs from 14 work orders were not made to
the tenants’ account from 30 to 196 days after the work order service was provided.
Establishing tenant receivables related to maintenance work orders more than six months
after the work was completed means the Housing Authority does not have an accurate
accounting of their tenant receivable assets at any single point in time. In addition, Low-
Rent public housing tenants could vacant their assigned unit prior to the tenant receivable
being established, thus creating a potential for loss.
Tenant Accounts Receivable: The GHA and the Weld County Housing Authority has not
been recording its accounts receivable balances from its Section 8 Housing Choice Voucher
Program tenants on the appropriate accounting records. Instead, receivables from its Section
8 Housing Choice Voucher Program tenants are being maintained on an unofficial
accounting record kept by the particular Housing Authority’s program administrator. As
such the identity, control and tracking of the Housing Authorities’ tenant receivables is
greatly diminished.
Further analysis and corrective action is needed in connection with these two areas.
Accordingly, these are being presented for HUD’s further review and action as considered
necessary.
33 2004-DE-1003
Issues Needing Further Study and Consideration
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2004-DE-1003 34
Appendix A
Schedule of Questioned Costs
Recommendation Unsupported
Number Type of Questioned Cost Costs 1/
1D Income Disregard Program $7,226
1E Security Deposits $1,100
2B Repayment Agreement $1,040
2C Administrative Fees $ 704
1/ Unsupported costs are costs charged to a HUD-financed or HUD-insured program or
activityand eligibility cannot be determined at the time of audit. The costs are not supported by
adequate documentation or there is a need for a legal or administrative determination on the
eligibility of the costs. Unsupported costs require a future decision by HUD program officials.
This decision, in addition to obtaining supporting documentation, might involve a legal
interpretation or clarification of Departmental policies and procedures.
35 2004-DE-1003
Appendix A
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2004-DE-1003 36
Appendix B
Auditee Comments
37 2004-DE-1003
Appendix B
2004-DE-1003 38
Appendix B
39 2004-DE-1003
Appendix B
2004-DE-1003 40
Appendix B
41 2004-DE-1003
Appendix B
2004-DE-1003 42
Appendix B
43 2004-DE-1003
Appendix B
2004-DE-1003 44
Appendix B
(Supporting documentation provided by the auditee was too voluminous to include in the audit
report. These documents were provided to the HUD Region 8 Office of Public Housing under
separate cover.)
45 2004-DE-1003
Appendix B
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2004-DE-1003 46
Appendix C
Distribution Outside of HUD
The Honorable Susan M. Collins, Chairman, Committee on Government Affairs
The Honorable Joseph Lieberman, Ranking Member, Committee on Government Affairs
The Honorable Thomas M. Davis, III, Chairman, Committee on Government Reform
The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform
Elizabeth Meyer, Senior Advisor, Subcommittee on Criminal Justice
Clinton C. Jones, Senior Counsel, Committee on Financial Services
Kay Gibbs, Committee on Financial Services
Mark Calabria, Committee on Banking, Housing, and Urban Affairs
W. Brent Hall, U.S. General Accounting Office
Steve Redburn, Chief Housing Branch, Office of Management and Budget
Linda Halliday, Department of Veterans Affairs, Office of Inspector General
47 2004-DE-1003
Housing Authority of the City of Greeley and Weld County Housing Authority, Greeley, Colorado
Published by the Department of Housing and Urban Development, Office of Inspector General on 2004-06-22.
Below is a raw (and likely hideous) rendition of the original report. (PDF)