oversight

Municipality of San Juan Housing Authority San Juan, Puerto Rico

Published by the Department of Housing and Urban Development, Office of Inspector General on 2005-09-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                                 Issue Date
                                                                       September 29, 2005
                                                                 Audit Case Number
                                                                       2005-AT-1015




TO:          Olga I. Saez, Director, Public and Indian Housing, San Juan Field Office, 4NPH


FROM:
             James D. McKay
             Regional Inspector General for Audit, 4AGA


SUBJECT: The Municipality of San Juan Housing Authority, San Juan, PR,
         Did Not Properly Administer Its Section 8 Housing Choice Voucher Program


                                     HIGHLIGHTS

 What We Audited and Why

              We audited the Municipality of San Juan Housing Authority’s (Authority) Section 8
              Housing Choice Voucher program as part of our strategic plan goals to reduce
              erroneous payments in rental assistance programs. The review was initiated in
              response to a request from the Department of Housing and Urban Development’s
              (HUD) San Juan Office of Public and Indian Housing. The San Juan office advised
              that it was not satisfied with the Authority’s overall performance in administering its
              Section 8 program. The objective of our audit was to determine whether the
              Authority had adequate controls to effectively administer the Section 8 Housing
              Choice Voucher program.

 What We Found


              The Authority did not have adequate controls to ensure tenants received the
              proper voucher size, assistance payments were correct, files were properly
              documented, and participants were properly selected from the waiting list. As a


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           result, the Authority made erroneous housing assistance payments totaling $9,601
           and could incur additional overpayments of $148,827.

What We Recommend
           We recommend that the director of the Office of Public and Indian Housing
           require the Authority to repay $9,601, less the $3,138 already recovered, for
           excessive and erroneous housing assistance payments and take measures to avoid
           future estimated overpayments of $148,827. The director should also require the
           Authority to review tenant files with inadequate income verifications, locate
           missing tenant files, and determine the appropriateness and eligibility of the
           $121,638 in housing assistance disbursed. Further, since the Authority failed to
           correct deficiencies identified by HUD in December 2002, HUD should reduce
           the Authority’s administrative fees earned by 10 percent retroactively to July
           2003 or about $413,327. HUD should continue to monitor the Authority and
           withhold 10 percent of the administrative fee, about $410,338, until the Authority
           complies with requirements. We also recommend that the director require the
           Authority to establish and implement controls to ensure it follows HUD
           requirements so that assistance payments are correct, files are properly
           documented, and participants are properly selected from the waiting list.

           For each recommendation without a management decision, please respond and
           provide status reports in accordance with HUD Handbook 2000.06, REV-3.
           Please furnish us copies of any correspondence or directives issued because of the
           audit.

Auditee’s Response


           We discussed the findings with the Authority during the audit and at the exit
           conference on September 9, 2005. The Authority provided its written comments
           to our draft report on September 16, 2005. In its response, the Authority
           generally agreed with the findings.

           The complete text of the Authority’s response, along with our evaluation of that
           response, can be found in appendix B of this report.




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                                            2
                            TABLE OF CONTENTS

Background and Objectives                                                          4

Results of Audit
      Finding 1: The Authority Did Not Properly Administer Its Section 8 Housing   5
      Choice Voucher Program

Scope and Methodology                                                              11

Internal Controls                                                                  13

Followup on Prior Audits                                                           14

Appendixes
   A. Schedule of Questioned Costs and Funds to Be Put to Better Use               15
   B. Auditee Comments and OIG’s Evaluation                                        16
   C. Criteria                                                                     26
   D. Summary of File Deficiencies                                                 28




                                            3
                     BACKGROUND AND OBJECTIVES

The Municipality of San Juan Housing Authority (Authority) administers about 4,000 housing
choice vouchers within San Juan and its vicinity. The annual assistance payments and
administrative fees approach $24 million. The Authority’s Subsidized Housing Office was
assigned the responsibility of administering the Section 8 program. The Authority’s books and
records for the Section 8 program are maintained at 1205 Ponce de Leon Avenue, San Juan,
Puerto Rico.

We audited the Authority’s Section 8 Housing Choice Voucher program in response to a request
from the Department of Housing and Urban Development’s (HUD) San Juan, Puerto Rico,
Office of Public and Indian Housing. The San Juan office advised that it was not satisfied with
the Authority’s overall performance in administering its Section 8 program. The San Juan office
conducted several reviews during the past few years that continually identified weaknesses in the
Authority’s procedures.

The objective of our audit was to determine whether the Authority had adequate controls to
effectively administer the Section 8 Housing Choice Voucher program. This audit is part of an
ongoing review of the Authority.




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                                                4
                                RESULTS OF AUDIT

Finding 1: The Authority Did Not Properly Administer Its Section 8
           Housing Choice Voucher Program
The Authority paid $3,348 in excess subsidies for tenants with oversize vouchers and could incur
additional overpayments of $148,827. In addition, the Authority made erroneous housing
assistance payments totaling $6,253, did not comply with record-keeping requirements, and did
not select participants from the waiting list in accordance with HUD requirements. The
deficiencies occurred because the Authority did not establish and implement adequate controls to
ensure tenants received the proper voucher size, assistance payments were correct, files were
properly documented, and participants were properly selected from the waiting list. Thus, the
Authority cannot assure it only paid subsidies for eligible families or in the appropriate amounts
and selected applicants in accordance with HUD requirements.



 Wrong Size Vouchers


               The Authority has 354 tenants with Section 8 vouchers larger than the number of
               people in their households (overhoused tenants). Of the 354 overhoused tenants,
               10 tenants are overhoused with excessive subsidy payments, and 282 tenants have
               the potential to receive subsidy overpayments. This overhousing occurred
               because the Authority does not have adequate procedures in place to ensure that
               its tenants receive the proper voucher size.

               HUD’s Housing Choice Voucher Guidebook explains that when determining unit
               size, the subsidy standards must provide for the smallest number of bedrooms
               needed to house a family without overcrowding. In addition, the Authority’s
               administrative plan provides that tenants will be assigned units based on the
               number of people in their households.

               A sample of 13 overhoused tenants showed that the Authority issued the wrong
               size voucher to 10 families from the beginning of the tenants’ participation in the
               Section 8 program. The tenants had a Section 8 voucher larger than the number
               of people in their households. As a result, the Authority used the incorrect
               payment standard and/or utility allowance to calculate the housing assistance.
               The housing authority calculates the maximum subsidy allowable, based on the
               payment standard and gross rent of the unit. We found the Authority incorrectly
               used a higher payment standard and/or gross rent, causing the payment of $3,348
               in excess subsidy payments from the admission date to June 2005. The Authority
               could incur additional overpayments of $3,939, during the remaining contract
               period for the above 10 tenants, if it does not implement corrective measures.


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           Based on the results of our sample, we recalculated the housing assistance for the
           remaining 341 overhoused tenants to determine the possible effect on the Section
           8 program. To recalculate the housing assistance, we used the payment standard
           and utility allowance that applied to tenants based on the number of people in
           their households. Our analysis showed that 282 of the 341 overhoused tenants
           had the potential to have excess subsidy payments. The Authority may have
           applied the incorrect payment standard and/or gross rent to calculate housing
           assistance. We estimate that the Authority may pay $144,888 in excess subsidies
           for the tenants with oversize vouchers over the next 12 months.

Housing Assistance Was
Improperly Paid

           Our examination of 29 files disclosed the Authority did not properly determine or
           verify housing assistance payments. As a result, the Authority made erroneous
           assistance payments totaling $6,253. It made duplicate subsidy payments of
           $4,813 and made errors causing the overpayment of $1,440 in housing assistance.
           The Authority recovered $3,138 during the audit, leaving $3,115 to be repaid.
           We also found the Authority did not follow HUD requirements and its own
           policies when verifying a family’s income.

              •     Duplicate subsidy. The Authority did not disburse housing assistance
                    subsidies for only eligible purposes. Two tenants moved to new units, but
                    the Authority continued to make rental payments to former landlords and
                    paid utility allowance reimbursement to tenants. When tenants moved to
                    new units, the Authority issued a new voucher without canceling the
                    original. Therefore, the same tenant was in the Authority’s housing
                    assistance payment register with two active vouchers. This resulted in
                    duplicate subsidy payments of $4,813. During the audit, the Authority
                    initiated corrective measures and recovered $3,138 of the duplicate
                    subsidies, leaving an uncollected balance of $1,675.

                                                   Duplicate Recovered
                                  File number      subsidy (as of June 2005)   Balance
                      Tenant A    PI-050, 7076      $3,252      $3,138          $ 114
                      Tenant B     1085, 7317       $1,561              0       $1,561
                                      Total         $4,813      $3,138          $1,675

              •     Subsidy errors. The Authority did not correctly calculate the housing
                    assistance payment in three tenant files because it did not properly
                    determine tenants’ annual income or used the incorrect fair market rent
                    when calculating assistance payments. Errors in three files resulted in the
                    Authority making net overpayments of $1,440. The tenant’s annual


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                          income was understated in two files, and the fair market rent was
                          overstated in another.

                                  File number         Overpayment
                                      2299                    $864
                                      9677                     552
                                      9123                      24
                                      Total                 $1,440

                      •   Inadequate verification of income. In 21 tenant files, the Authority did
                          not consistently follow HUD requirements and its own policies and
                          procedures when verifying a family’s income. 1 As a result, the Authority
                          cannot ensure the propriety and eligibility of $80,199 in housing
                          assistance paid from the last certification to June 2005.

                          For example, the Authority did not obtain employment information
                          directly from the source and allowed four tenants to handle verification
                          forms. The written verification documents must be supplied directly to the
                          independent source by the housing authority and be returned directly to
                          the housing authority from the independent source. The tenant shall not
                          hand carry documents to or from the independent source. Authority
                          officials informed us the employment verification was provided to tenants
                          to help accelerate the certification process. This was not an acceptable
                          explanation for not performing an integral component of its Section 8
                          Housing Choice Voucher program responsibilities.

                          We also found that notarized statements and/or copies of tax returns were
                          not obtained to verify the income of two self-employed tenants. When
                          third-party verification is not available, the housing authority should
                          always request a notarized tenant declaration that includes a perjury
                          statement. The files only included general statements of the tenant’s
                          annual earnings without the Authority documenting the efforts made to
                          obtain a higher level of verification. In two other files, there was
                          information indicating tenants could be underreporting income, but the
                          Authority did not respond appropriately to clarify or resolve the issue.
                          The Authority is required to verify the accuracy of income information
                          received.


    Files Were Not Properly
    Documented

                 The Authority did not comply with HUD record-keeping requirements that permit
                 a speedy and effective audit. During our examination, the Authority could not

1
     Appendix D provides a chart summarizing the deficiencies found.


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               locate tenant files, housing assistance payment contracts, and consent forms
               signed by tenants.

                    •   Missing files. The Authority could not locate nine Section 8 tenant files
                        for our review. As a result, it cannot ensure the propriety and eligibility of
                        $41,439 in housing assistance paid from the last certification to June 2005.
                        The missing files were as follows:

                               File number      Housing assistance payments
                                 MB-081                              $1,344
                                 MB-084                               7,752
                                        *
                                   6033                               2,964
                                   PI-029                             2,975
                                   9055                               6,250
                                        *
                                   6033                               7,755
                                   4016                               8,588
                                   4104                               2,060
                                   0709                               1,751
                                          Total                     $41,439
                               *
                                   Duplicate case file number.

                    •   Missing contracts. In 10 tenant files, the Authority did not provide a
                        properly executed housing assistance payment contract. The housing
                        assistance payment contract is the written agreement between the Authority
                        and the owner of the unit occupied by the Housing Choice Voucher program
                        participant. Housing authorities may not pay any housing assistance
                        payment to the owner until the contract has been executed. The housing
                        assistance payment contract must be executed no later than 60 calendar days
                        from the beginning of the lease term. Without a properly executed contract,
                        the Authority would not be able to enforce landlord obligations under the
                        Section 8 Housing Choice Voucher program. The Authority could not
                        explain why the contracts were missing.

                    •   Consent forms not signed. In three tenant files, the Authority did not
                        ensure that tenants signed HUD Form 9886, Authorization for the Release of
                        Information. HUD Form 9886 allows the Authority and HUD to obtain
                        income information about applicants and participants. All heads of
                        households and any other member who is 18 years of age or older are
                        required to sign the consent form. The Authority’s failure to ensure that all
                        participants sign the consent form increases HUD’s risk to the Section 8
                        Housing Choice Voucher program. Without the consent forms properly
                        signed, the Authority cannot independently verify the family’s income and
                        assure the eligibility of participants.




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     Tenants Not Properly Selected
     from Waiting List


                   The Authority did not select participants from the waiting list in accordance with
                   HUD requirements and in compliance with admission policies in the Authority’s
                   administrative plan. As a result, the Authority may have denied other eligible
                   applicants an opportunity to receive housing assistance. During the review, we
                   identified four families that were recently admitted to the program but were not
                   on the Authority’s housing choice voucher waiting list.

                                 File number       Admission date
                                     9677           July 16, 2004
                                     2005           Nov. 1, 2004
                                     0706           Dec. 5, 2004
                                     1928           Jan. 6, 2005

                   We also found 16 families selected for admission to the program in an order
                   different from the order on the waiting list. When admitting these families to the
                   program, the Authority did not consider or ignored other applicants with similar
                   needs that were on the waiting list for a longer period. The Authority did not
                   provide documentation showing the method of selecting the applicants and that it
                   was done in accordance with HUD requirements and the administrative plan.

     Conclusion



                   Our examination of tenant files showed the Authority did not have proper controls
                   in place to assure it administered the Section 8 Housing Choice Voucher program
                   in an effective manner and in compliance with HUD requirements. The lack of
                   adequate controls allowed the Authority to issue the wrong size voucher, make
                   incorrect housing assistance payments, improperly document tenant files, and
                   improperly select tenants from the waiting list. The deficiencies were similar to
                   those identified in three HUD reviews. 2 Despite the fact that HUD has provided
                   technical assistance, the Authority has not made significant progress to improve
                   its performance. Therefore, we recommend that HUD reduce the Authority’s
                   administrative fees by 10 percent retroactively to July 2003, about $413,327.
                   Further, we recommend that HUD continue to withold 10 percent of future
                   administrative fees, about $410,338, until the Authority complies with program
                   requirements.



 2
       In December 2002, HUD performed a rental integrity monitoring review and followup reviews in November
       2003 and 2004.


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Recommendations

           We recommend that the director, Office of Public and Indian Housing,

           1A   Require the Authority to reimburse the Section 8 Housing Choice Voucher
                program from nonfederal funds $3,348 in excess subsidies and $6,253, less
                the $3,138 recovered during the audit, for the erroneous housing assistance
                payments.

           1B   Require the Authority to review the identified overhoused tenants and
                prevent future estimated overpayments of $148,827.

           1C   Require the Authority to review identified tenants with inadequate income
                verifications, determine the appropriateness and eligibility of $80,199
                disbursed in housing assistance, and repay the Section 8 Housing Choice
                Voucher program from nonfederal funds any amounts determined ineligible.

           1D   Require the Authority to locate the missing tenant files and determine the
                appropriateness and eligibility of the $41,439 disbursed in housing
                assistance and repay the Section 8 Housing Choice Voucher program from
                nonfederal funds any amounts determined ineligible.

           1E   Reduce the Authority’s administrative fees by 10 percent retroactively to
                July 2003, about $413,327.

           1F   Continue to monitor the Authority and withhold 10 percent of administrative
                fees, about $410,338, until the Authority complies with requirements of the
                Section 8 Housing Choice Voucher program.

           1G   Require the authority to establish and implement controls to ensure it
                follows HUD requirements so that assistance payments are correct, files are
                properly documented, and participants are properly selected from the
                waiting list.




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                                          10
                           SCOPE AND METHODOLOGY


Our audit objective was to determine whether the Authority had adequate controls to effectively
administer the Section 8 Housing Choice Voucher program. To accomplish our objective, we

•       Obtained and reviewed relevant HUD regulations and Authority guidelines.
•       Interviewed HUD program staff and reviewed their monitoring reports.
•       Interviewed Authority staff.
•       Obtained and reviewed the Authority’s latest independent public accountant report.
•       Reviewed a sample of Section 8 tenant files.
•       Reviewed the Authority’s controls related to the administration of its Section 8 program.

We obtained a download of the Authority’s current units from the housing assistance payment
register. There were 4,131 units as of April 1, 2005. We selected and performed a detailed
review of a sample of 25 tenant files to verify that the Authority properly determined eligibility,
subsidy payments and to test waiting list selection. 3 We verified that each file contained
adequate support for tenant income, utility allowances, deductions, payment standards, and
contract rent. Using this information, we recomputed the tenant’s assistance payments and
compared them to the Authority’s assistance payment calculations to determine any variances.
We also reviewed four tenants with possible duplicate housing assistance payments.

During the initial phase of the audit, we identified three tenants who had vouchers larger than the
number of people in their households (overhoused tenant). As a result, we decided to expand the
scope of our review to determine the number and effect of overhoused tenants. We applied a
computer formula to the Authority’s data and identified 354 cases of families who possessed a
Section 8 housing choice voucher with more bedrooms than their family size. Of the 354
overhoused tenants, we selected 13 tenants to verify that the Authority issued proper voucher
sizes to tenants. We also recalculated the housing assistance for the remaining 341 overhoused
tenants to determine the possible effect on the Section 8 program. To recalculate the housing
assistance, we used the payment standard that applied to tenants based on the number of people
in their households. We accepted and did not reverify the Authority’s calculation for income and
deductions for the overhoused tenants.

The audit generally covered the period of July 2003 through March 2005, and we extended the
period as needed to accomplish our objectives. We conducted our fieldwork from March
through June 2005 at the Authority’s offices in San Juan, Puerto Rico.




3
    We selected 23 tenants who were admitted to the Section 8 program between October 2003 and March 2005
    and two admitted in June and August 2002.


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To achieve our audit objectives, we relied in part on computer-processed data contained in the
Authority’s database. Although we did not perform a detailed assessment of the reliability of the
data, we did perform a minimal level of testing of these data and found them to be adequate for
our purposes. The results of the audit apply only to the items selected and cannot be projected to
the universe or population.

We conducted the audit in accordance with generally accepted government auditing standards.




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                             INTERNAL CONTROLS

Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being achieved:

   •   Effectiveness and efficiency of operations,
   •   Reliability of financial reporting, and
   •   Compliance with applicable laws and regulations.

Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance.



 Relevant Internal Controls
              We determined the following internal controls were relevant to our audit objectives:

                  •   Compliance with laws, regulations, policies, and procedures that
                      management has implemented to reasonably assure that resource use is
                      consistent with laws and regulations.

                  •   Policies and procedures that management has implemented to reasonably
                      assure that resources are safeguarded against waste, loss, and misuse.

              We assessed the relevant controls identified above.

              A significant weakness exists if management controls do not provide reasonable
              assurance that the process for planning, organizing, directing, and controlling
              program operations will meet the organization’s objectives.

 Significant Weaknesses

              Based on our review, we believe the following item is a significant weakness:

                  •   The Authority did not establish and implement adequate controls to ensure
                      tenants received the proper voucher size, housing assistance payments
                      were correct, files were properly documented, and tenants were properly
                      selected from the waiting list (see finding 1).




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                                               13
                     FOLLOWUP ON PRIOR AUDITS


Prior Independent Public
Accountant Report Findings

           The most recent audit of the Authority’s financial statements ending June 30, 2004,
           contained findings that the Authority’s Section 8 tenant files were missing,
           incomplete, and did not show rationale used to admit applicants to the Section 8
           program. Our audit determined that these conditions had not been corrected.




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                                            14
                APPENDIXES

Appendix A

                   SCHEDULE OF QUESTIONED COSTS
                  AND FUNDS TO BE PUT TO BETTER USE

                                                                      Funds to be put to
              Recommendation        Ineligible 1/   Unsupported 2/      better use 3/
                      1A            $     9,601
                      1B                                                      $ 148,827
                      1C                                 $ 80,199
                      1D                                   41,439
                      1E                413,327
                      1F                                                        410,338

                 Total              $ 422,928            $ 121,638            $ 559,165




1/       Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
         that the auditor believes are not allowable by law; contract; or federal, state, or local
         policies or regulations.

2/       Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
         or activity when we cannot determine eligibility at the time of audit. Unsupported costs
         require a 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.

3/       “Funds to be put to better use” are quantifiable savings that are anticipated to occur if an
         Office of Inspector General (OIG) recommendation is implemented, resulting in reduced
         expenditures at a later time for the activities in question. This includes costs not incurred,
         deobligation of funds, withdrawal of interest, reductions in outlays, avoidance of
         unnecessary expenditures, loans and guarantees not made, and other savings.




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                                                    15
Appendix B

        AUDITEE COMMENTS AND OIG’S EVALUATION


Ref to OIG Evaluation   Auditee Comments




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                    17
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                    18
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                    19
Comment 1




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                    21
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                    22
Comment 2




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                    23
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                    24
                       OIG Evaluation of Auditee Comments




Comment 1     We agree with the Authority that changes in the computer system might
              improve the chances of detecting duplicate subsidy payments. However, the
              Authority must also ensure it has appropriate procedures for canceling
              vouchers when new vouchers are issued.

Comment 2     The implementation of corrective measures should not be conditioned to the
              approval of additional HUD funding as proposed by the Authority. HUD
              already paid the Authority about $4 million in administrative fees during the
              last two years to administer the Authority’s Section 8 Housing Choice
              Voucher program. We are currently recommending a reduction in
              administrative fees until the Authority can establish it has the ability to carry
              out the housing choice voucher program in accordance with HUD regulations.
              HUD will make the determination on how to best approach the corrective
              action needed to get the Authority operating appropriately.




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                                           25
Appendix C

                                         CRITERIA


24 CFR [Code of Federal Regulations] 5.240(c)

The responsible entity must verify the accuracy of the income information received from the
family and change the amount of the total tenant payment as appropriate, based on such
information.

24 CFR [Code of Federal Regulations] 982.152(d)

HUD may reduce or offset any administrative fee to the public housing authority, in the amount
determined by HUD, if the public housing authority fails to perform its administrative
responsibilities correctly or adequately under the program.

24 CFR [Code of Federal Regulations] 982.158(a)

The public housing authority must maintain complete and accurate accounts and other records
for the program in accordance with HUD requirements in a manner that permits a speedy and
effective audit.

24 CFR [Code of Federal Regulations] 982.204(a)

The public housing authority must select participants from its waiting list, except for special
admissions.

24 CFR [Code of Federal Regulations] 982.516(a)

The authority must conduct a reexamination of family income and composition at least annually
and document in the tenant file third-party verification or why third-party verification was not
available.

Notice PIH [Public and Indian Housing] 2004-01 (HA), Verification Guidance

The notice provides instructions on HUD-established verification guidance and requires public
housing authorities to implement procedures to ensure compliance with the verification policies.
It also outlines the verification procedures a public housing authority must use when verifying
income and deductions to calculate rent.




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                                                26
Notice PIH [Public and Indian Housing] 2005-7 (HA), Rental Integrity Monitoring
Disallowed Costs and Sanctions under the Rental Housing Integrity Improvement Project
Initiative

The notice highlights the importance of timely and accurate income and rent determinations by
public housing authorities and the consequences for failure to identify and correct income and
rent determination deficiencies. Public housing authorities must identify and implement
corrective actions or rectify errors in meeting program requirements uncovered during rental
integrity monitoring reviews. In the event that a public housing authority fails to comply with
the requirements of the rental integrity monitoring review or other reviews, HUD will impose
sanctions on the public housing authority pursuant to section 6(j)(4)(A)(v) of the U.S. Housing
Act of 1937 and 24 CFR [Code of Federal Regulations] 982.152(d) regarding voucher programs.

If, as a result of a rental integrity monitoring review, a public housing authority does not
implement its corrective actions within the timeframes approved by the field office, 10 percent of
its monthly scheduled administrative fee advance will be withheld, beginning the month the field
office makes the sanction effective and lasting until the public housing authority has complied
with the program requirements.

Authority’s Administrative Plan
The Authority’s administrative plan establishes local policies for items not specifically covered
by federal regulations and acknowledges the Authority’s responsibility for complying with HUD
regulations.




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                                               27
Appendix D

                   SUMMARY OF FILE DEFICIENCIES


                                                 Missing       Housing
                    Inadequate Inadequate        housing      assistance   HUD Form
           File      earnings    waiting list   assistance   calculation 9886 not signed
         number     verification  selection      contract       error       by tenant
           1449          X            X
           2005          X            X                                        X
           1928          X            X                          X
           9123          X                           X           X
           6935          X            X              X
           9376          X
          PI-084                                     X
           6253         X             X              X
           0848         X             X              X
           6320         X             X
           9529         X             X              X
           6728         X
           9231         X             X              X                         X
           1551         X             X              X                         X
           0258         X
           0344         X             X                          X
           0392         X             X
           0525         X             X
           1704         X             X
           2299         X             X                          X
           9503         X             X                          X
           0706                       X
           9467                       X
           9677                       X              X           X
           0903         X             X              X
          Total         21            20             10          6              3




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