Issue Date February 7, 2011 Audit Report Number 2011-CH-1005 TO: Steven E. Meiss, Director of Public Housing Hub, 5APH FROM: Ronald Farrell, Acting Regional Inspector General for Audit, 5AGA SUBJECT: The Housing Authority of the County of Cook, Chicago, IL, Needs To Improve Its Controls Over Its Administration of Section 8 Housing Assistance Payments to Its Nonprofit Units HIGHLIGHTS What We Audited and Why We audited the Housing Authority of the County of Cook’s (Authority) nonprofit development activities. The audit was part of the activities in our fiscal year 2010 annual audit plan. We selected the Authority’s nonprofit development activities based on a citizen’s complaint forwarded to our office from the County of Cook, IL’s Office of the Independent Inspector General. Our objective was to determine whether the Authority administered its Section 8 housing assistance payments to its nonprofit’s units in accordance with the U.S. Department of Housing and Urban Development’s (HUD) requirements and the Authority’s Section 8 administrative plan. What We Found The Authority’s administration of its Section 8 Housing Choice Voucher program (program) housing assistance payments to its nonprofit instrumentality’s, Turnstone Development (Turnstone), units was inadequate. The Authority failed to collect more than $30,000 in housing assistance payments made to an incorrect program landlord. The Authority also miscalculated Program housing assistance payments for its project-based vouchers allocated to 21 Turnstone units, resulting in the underpayment of more than $10,000 in housing assistance to 21 households. Further, the Authority failed to recover housing assistance payments made for four Program households after they were deceased, resulting in more than $4,000 in overpayments to Turnstone units. We informed the Authority’s executive director and the Director of HUD’s Chicago Office of Public Housing of minor deficiencies through a memorandum, dated February 2, 2011. What We Recommend We recommend that the Director of HUD’s Chicago Office of Public Housing require the Authority to (1) reimburse its program more than $30,000 from non- Federal funds for the housing assistance payments owed by an incorrect program landlord, (2) reimburse the 21 program households more than $10,000 from program funds for the underpayment of housing assistance, and (3) reimburse its program more than $4,000 from non-Federal funds for the housing assistance payments made for deceased households. 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 provided our review results and supporting schedules to the Director of HUD’s Chicago Office of Public Housing and the Authority’s executive director during the audit. We provided our discussion draft audit report to the Authority’s executive director, its board chairman, and HUD’s staff during the audit. We held an exit conference with the executive director on January 7, 2011. We asked the executive director to provide written comments on our discussion draft audit report by January 14, 2011. The executive director provided written comments, dated January 14, 2011. The director partially agreed with our findings and recommendations. The complete text of the written comments, except for the 70 pages of supporting documentation that were not necessary for understanding the director’s comments, along with our evaluation of that response, can be found in appendix B of this report. We provided the Director of HUD’s Chicago Office of Public Housing with a complete copy of the Authority’s written comments plus the 70 pages of supporting documentation. 2 TABLE OF CONTENTS Background and Objective 4 Results of Audit Finding 1: The Authority Failed to Collect Housing Assistance Payments Made to an Incorrect Program Landlord 6 Finding 2: The Authority Miscalculated Housing Assistance Payments for Its Section 8 Project-Based Vouchers 8 Finding 3: The Authority Failed to Recover Housing Assistance Payments for Deceased Program Households 10 Scope and Methodology 13 Internal Controls 15 Appendixes A. Schedule of Questioned Costs and Funds To Be Put to Better Use 17 B. Auditee Comments and OIG’s Evaluation 18 C. Federal Requirements and Authority’s Program Administrative Plan 25 3 BACKGROUND AND OBJECTIVE The Housing Authority of the County of Cook (Authority) was established in 1946 as a municipal corporation. It is responsible for promoting adequate and affordable housing, economic opportunity, and a suitable living environment free from discrimination. The commissioners created the Authority because Cook County was experiencing population growth but did not have sufficient housing to meet the need. The Authority initially focused on improving existing housing conditions, but with the 1949 U.S. Housing Act, it was given aid to construct and maintain housing for low-income families. By 1953, the Authority had programs in many Cook County suburban communities including Robbins, Chicago Heights, and Summit. By 1961, public housing senior residences were also underway. As the need for affordable housing increased, the Authority continued to build and maintain its public housing units. The Authority is governed by a six-member board of commissioners appointed by the Cook County board president and confirmed by the full board for 5-year terms. The Authority’s executive director, appointed by the board of commissioners, is responsible for executing the policies established by the board of commissioners. As of November 2010, the Authority managed more than 2,000 public housing units and nearly 12,000 Section 8 Housing Choice Voucher program vouchers. Turnstone Development (Turnstone), an Illinois 501(c)(3) nonprofit corporation that serves as an instrumentality of the Authority, was created on October 8, 1998. It is responsible for providing new, affordable housing opportunities for families and the elderly throughout suburban Cook County. Turnstone is governed by a five-member board of commissioners that consists of four Authority board commissioners and the Authority’s executive director. Turnstone has an ownership interest in eight developments that receive Section 8 housing assistance payments from the Authority. The Authority made Program housing assistance payments of nearly $4.1 million from November 2002 through February 2010 for 228 of the 877 Turnstone units located in the eight developments. We conducted walkthrough observations of 16 Turnstone units receiving housing assistance payments from 4 developments on June 2 and 3, 2010. The units passed an annual housing quality standards inspection conducted by the Authority within 31 to 79 days from the dates we conducted the walkthrough observations. The 16 Turnstone units passed the review of our appraiser. The citizen complaint forwarded to our office from the County of Cook’s Office of the Independent Inspector General alleged that Turnstone’s funds were being commingled with the Authority’s funds and the Authority was using Turnstone’s procured vendors without following the appropriate procurement policies. We reviewed Turnstone’s financial records and randomly selected 30 transactions (15 cash receipts and 15 cash disbursements) from its general ledgers. We determined that Turnstone adequately maintained the 30 transactions separate from the Authority’s financial records and bank accounts. Additionally, we randomly selected six vendors that the Authority shared with Turnstone and determined that the Authority followed 4 HUD’s procurement requirements in contracting with the vendors. Based on these results, we determined that the commingling of funds and procurement areas did not warrant further review. Our objective was to determine whether the Authority administered its Section 8 housing assistance payments to Turnstone’s units in accordance with the U.S. Department of Housing and Urban Development’s (HUD) requirements and the Authority’s Section 8 administrative plan. 5 RESULTS OF AUDIT Finding 1: The Authority Failed to Collect Housing Assistance Payments Made to an Incorrect Program Landlord The Authority failed to collect housing assistance payments electronically deposited into the bank account of an incorrect program landlord. The housing assistance payments were not collected because the Authority failed to enforce the repayment agreement that was drafted for the incorrect program landlord. As a result, the Authority was owed more than $30,000 in housing assistance payments. Housing Assistance Payments Owed to the Authority Were Not Collected The Authority electronically deposited housing assistance payments totaling $58,456 on October 1, October 15, and November 1, 2008, for 44 program households residing in the Thomas Place development, rental property in which Turnstone has an ownership interest, into the bank account of an incorrect program landlord who was not the owner of Thomas Place. This error occurred because the Authority’s staff mistakenly entered the landlord’s bank account information into its computer system as the bank account for the owner of the Thomas Place development. Thomas Place’s property manager notified the Authority in November 2008 that it had not received housing assistance payments for October and November 2008. Once the Authority became aware of this issue, it paid Thomas Place for the $58,456 in housing assistance that it did not receive and instructed its financial institution to recall the housing assistance which was mistakenly paid to the incorrect program landlord. However, when an attempt was made to reverse the electronic transfer of funds, the $58,456 in housing assistance payments made to the landlord had been moved out of the account. The Authority’s former chief financial officer drafted a repayment agreement which stipulated that the incorrect program landlord would make a lump sum payment of $15,000 to the Authority by June 30, 2009. In addition, the Authority would withhold the landlord’s monthly housing assistance payment for a program unit and the landlord would make an additional monthly repayment of $500 beginning July 1, 2009. As of December 2010, the landlord had not signed the repayment agreement. The landlord made a lump sum payment of $10,000 in August 2009 and had not made any monthly payments. The Authority withheld monthly housing assistance payments totaling $18,022 owed to the landlord from April 2009 through October 2010. As of December 2010, the Authority was owed $30,434 from the landlord ($58,456 minus $10,000 minus $18,022). On December 30, 2010, the Authority notified the landlord indicating that unless the 6 landlord made an additional payment of $15,000 and entered into a repayment agreement by January 15, 2011, the Authority would proceed to file a formal complaint for the amount owed. Conclusion As a result of the Authority’s failure to enforce a repayment agreement, the Authority was owed more than $30,000 in housing assistance payments. Recommendation We recommend that the Director of HUD’s Chicago Office of Public Housing require the Authority to 1A. Pursue collection of the remaining $30,434 of inappropriate housing assistance from the program landlord. If the landlord fails to repay, the Authority should reimburse its program the applicable amount from non- Federal funds. 7 Finding 2: The Authority Miscalculated Housing Assistance Payments for Its Section 8 Project-Based Vouchers The Authority miscalculated housing assistance payments for 21 of its 40 Section 8 project- based vouchers allocated to the Whistler Crossing and Wisdom Village developments, rental properties in which Turnstone has an owner interest. The miscalculated housing assistance payments were made because the Authority’s staff was not familiar with HUD’s requirements regarding the calculation of housing assistance payments for project-based vouchers. As a result, the Authority underpaid more than $10,000 in housing assistance for 21 households. The Authority Miscalculated Housing Assistance Payments for Its Project-Based Vouchers We reviewed the housing assistance payment calculations for the Authority’s 40 Section 8 project-based households. The Authority made housing assistance payments totaling $330,456 for the 40 households from July 2007 through February 2010. Our review was limited to the information in the Authority’s household files. For the 40 households, the Authority calculated housing assistance payments by subtracting the total tenant payment from the lower of the payment standard for the family or the gross rent. This formula is required by HUD for calculating housing assistance payments for tenant-based vouchers, not project-based vouchers. The instruction booklet to the form HUD-50058 indicates that for project-based vouchers, housing assistance payments are calculated by subtracting the total tenant payment from the gross rent. Therefore, the payment standard does not impact the calculation of housing assistance payments for project-based vouchers. As a result, the Authority miscalculated housing assistance payments and made underpayments totaling $10,688 to 21 of its 40 households. An Incorrect Section of the Form HUD-50058 Was Used by the Authority The miscalculations of housing assistance payments for the Section 8 project- based vouchers occurred because Authority staff used section 12 (section used to calculate for tenant-based vouchers) rather than section 11 (section used to calculate for project-based vouchers). According to the Authority’s executive director, the miscalculations were made because staff was not familiar with all of the requirements applicable for project-based vouchers since they make up a small percentage of the Authority’s Section 8 program. 8 The Authority Corrected the Issue We informed the Authority’s executive director on June 16, 2010, that the incorrect section of the form HUD-50058 was used for the calculation of the Authority’s Section 8 project-based vouchers. The Authority’s executive director issued a memorandum to the Authority’s staff on June 17, 2010, instructing that it use section 11 of the form HUD-50058 when calculating the housing assistance payments for project-based vouchers. We performed searches in HUD’s Public and Indian Housing Information Center database for the 40 project-based vouchers on June 30, 2010, and determined that as of June 25, 2010, the Authority was using section 11 of the form HUD-50058 to calculate the housing assistance payments for its Section 8 project-based vouchers. Conclusion As a result of using the incorrect section of the form HUD-50058 to calculate housing assistance payments for the Authority’s Section 8 project-based vouchers, the Authority underpaid more than $10,000 in housing assistance for 21 households. The 21 households subsequently overpaid $10,688 for their rent. Recommendation We recommend that the Director of HUD’s Chicago Office of Public Housing require the Authority to 2A. Reimburse the 21 households cited in this finding $10,688 from its Section 8 program for the underpayment of housing assistance. 9 Finding 3: The Authority Failed to Recover Housing Assistance Payments Made for Deceased Program Households The Authority failed to recover housing assistance payments made for four program households for the month(s) following the households’ date of death. This condition occurred because the Authority lacked adequate procedures and controls to ensure that it appropriately followed HUD’s requirements regarding the payment of housing assistance for deceased households. As a result, it overpaid more than $4,000 in housing assistance. Housing Assistance Payments Were Improperly Provided for Deceased Program Households We reviewed the Social Security numbers of the 264 program households receiving program housing assistance payments from May 2007 through February 2010 that resided in Turnstone’s units to determine whether payments were made for deceased households. The Social Security numbers for nine households were associated with deceased individuals. For five households, the Authority made housing assistance payments for the month(s) following the households’ date of death, which resulted in the overpayment of $7,273 in housing assistance. HUD’s regulations only allow housing assistance payments to be made to the owner while the family is residing in the contract unit. The Authority Lacked Adequate Procedures and Controls The overpayment of housing assistance occurred because the Authority lacked adequate procedures and controls to ensure that it appropriately followed HUD’s requirements regarding the payment of housing assistance for deceased households. The Authority was notified of the program household’s date of death for four of the five households. The Authority did not recover the housing assistance payments for three of the four households since it considered these units in which the households resided in to be project-based units and made vacancy housing assistance payments to owners of the developments for up to 2 months following the program households’ date of death. However, these units were not project- based since the developments housing the three units did not receive a HUD- approved subsidy layering review and a project-based housing assistance payments contract was not executed for these developments. In October 2008, HUD denied a waiver for the subsidy layering review and instructed the Authority to issue tenant-based vouchers. The Authority notified the landlords and tenants 10 of the change in February 2009. Therefore, the owners of the three units were not entitled to the vacancy loss payments. For the fourth household, the Authority properly terminated the household’s contract once it became aware of the household’s death. However, it did not make an entry in its financial records to recover the appropriate overpayments. For the fifth remaining household, the household’s date of death was April 25, 2010. However, the Authority was not notified of the program household’s death and made housing assistance payments from May 2010 thru October 2010. Public and Indian Housing Notice 2010-19 (effective on May 17, 2010) requires public housing agencies to monitor the deceased tenants report in HUD’s Enterprise Income Verification system on a monthly basis in order to ensure that public housing agencies are aware of potential housing assistance errors. A deceased tenants report generated on September 29, 2010 (generated by auditors) identified the household as deceased. The Authority did not monitor the deceased tenants report in HUD’s Enterprise Income Verification system. As a result of this audit, the Authority recouped the $2,514 in housing assistance payments that was overpaid for the fifth household on December 8, 2010. Additionally, the Authority’s executive director issued a memorandum to the Authority’s staff on December 22, 2010, instructing it to generate the deceased tenants report on a monthly basis to avoid housing assistance payments subsequent to the date of death. Conclusion As a result of the Authority’s failure to comply with HUD’s requirements, it improperly paid housing assistance. Specifically, it paid $7,273 in housing assistance after program households’ dates of death. Recommendations We recommend that the Director of HUD’s Chicago Office of Public Housing require the Authority to 3A. Reimburse its program $4,759 from non-Federal funds for the improper payment of housing assistance for four deceased households cited in this finding. 3B. Implement adequate procedures and controls to ensure that housing assistance paid for deceased households is recovered from the applicable program landlords. 11 3C. Monitor the deceased tenants report in HUD’s Enterprise Income Verification system on a monthly basis in order to identify potential housing assistance errors. 12 SCOPE AND METHODOLOGY To accomplish our objective, we reviewed Applicable laws; regulations; the Authority’s Program administrative plan; HUD’s program requirements at 24 CFR Parts 85, 982, and 983; Public and Indian Housing Notice 2010-19; and HUD’s Public and Indian Housing Information Center database. The Authority’s and Turnstone’s accounting records, annual audited financial statements for fiscal years 2006 through 2009, program household files, program housing assistance payments register, board meeting minutes, by-laws, computerized databases, and organizational charts. HUD’s files for the Authority. We also interviewed the Authority’s and Turnstone’s employees and HUD staff. Finding 2 We reviewed housing assistance calculations for 100 percent of the Authority’s 40 project-based households that received housing assistance from July 1, 2007 through February 28, 2010. Our review was limited to the information in the Authority’s household files. Finding 3 We ran the Social Security numbers for the 264 Section 8 program households receiving housing assistance payments from May 2007 through February 2010 that resided in Turnstone’s units through the Social Security Administration’s death index. Our search revealed that the Social Security numbers for nine of the households were associated with deceased individuals. We compared the date of deaths of the nine households to the last month in which housing assistance had been paid for as indicated in the Authority’s housing assistance payments register. This review revealed that for five households, the Authority made housing assistance payments for the month(s) following their date of death. We used Authority-generated reports from their housing assistance payments register to determine that from November 2002 through February 2010, the Authority paid nearly $4.1 million in housing assistance to 228 Turnstone units. We compared the monthly housing assistance payments identified in the Authority’s register to the monthly housing assistance payments calculated in the form HUD-50058 for 50 of the 228 Turnstone units. The monthly housing assistance payments in the register matched the amounts in the form HUD-50058 for all 50 Turnstone units. Therefore, we concluded that the data was reliable. We performed our on-site audit work between April and October 2010 at the Authority’s central office located at 175 West Jackson Boulevard, Suite 350, Chicago, IL. The audit covered the period January 1, 2008, through February 28, 2010, but was expanded when necessary. 13 We conducted the audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient and appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective. 14 INTERNAL CONTROLS Internal control is a process adopted by those charged with governance and management, designed to provide reasonable assurance about achievement of the organization’s mission, goals, and objectives with regard to Effectiveness and efficiency of operations, Reliability of financial reporting, and Compliance with applicable laws and regulations. Internal controls comprise the plans, policies, methods, and procedures used to meet the organization’s mission, goals, and objectives. Internal controls include the processes and procedures for planning, organizing, directing, and controlling program operations as well as the systems for measuring, reporting, and monitoring program performance. Relevant Internal Controls We determined that the following internal controls were relevant to our audit objective: Effectiveness and efficiency of operations - Policies and procedures that management has implemented to reasonably ensure that a program meets its objectives. Reliability of financial reporting - Policies and procedures that management has implemented to reasonably ensure that valid and reliable data are obtained, maintained, and fairly disclosed in reports. Compliance with applicable laws and regulations - Policies and procedures that management has implemented to reasonably ensure that resource use is consistent with laws and regulations. We assessed the relevant controls identified above. A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, the reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness and efficiency of operations, (2) misstatements in financial or performance information, or (3) violations of laws or regulations on a timely basis. 15 Significant Deficiency Based on our review, we believe that the following item is a significant deficiency: The Authority lacked adequate procedures and controls to ensure compliance with Federal requirements regarding the payment of housing assistance for deceased households (see finding 3). Separate Communication of Minor Deficiencies We informed the Authority’s executive director and the Director of HUD’s Chicago Office of Public Housing of minor deficiencies through a memorandum, dated February 2, 2011. 16 APPENDIXES Appendix A SCHEDULE OF QUESTIONED COSTS AND FUNDS TO BE PUT TO BETTER USE Recommendation Funds to be put number Ineligible 1/ to better use 2/ 1A $30,434 2A $10,688 3A 4,759 Totals $35,193 $10,688 1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity that the auditor believes are not allowed by law; contract; or Federal, State, or local policies or regulations. 2/ Recommendations that funds be put to better use are estimates of amounts that could be used more efficiently if an Office of Inspector General (OIG) recommendation is implemented. These amounts include reductions in outlays, deobligation of funds, withdrawal of interest, costs not incurred by implementing recommended improvements, avoidance of unnecessary expenditures noted in preaward reviews, and any other savings that are specifically identified. 17 Appendix B AUDITEE COMMENTS AND OIG’S EVALUATION Ref to OIG Evaluation Auditee Comments 18 Ref to OIG Evaluation Auditee Comments Comment 1 19 Ref to OIG Evaluation Auditee Comments Comment 2 Comment 3 20 Ref to OIG Evaluation Auditee Comments Comment 4 Comment 5 21 Ref to OIG Evaluation Auditee Comments 22 Ref to OIG Evaluation Auditee Comments Comment 2 Comment 3 23 OIG Evaluation of Auditee Comments Comment 1 We made changes to finding one to reflect the Authority’s letter dated December 30, 2010 which requested payment from the landlord for the amount owed. Comment 2 The Authority provided letters addressed to the 21 households as well as adjusting accounting entries which in its view supports that the households were reimbursed for their overpaid rent portion. However, since the Authority did not provide documentation that the checks were cashed, we still considered the overpaid rent to be a questionable cost. Comment 3 We made changes to finding two to reflect the appropriate overpaid household rent. Overpaid rent changed from $10, 714 to $10,688. Comment 4 The Authority argued that housing assistance payments made for three households following the households’ date of death were considered vacancy loss payments under the project based voucher program and therefore, eligible. HUD’s regulations at 24 CFR 982.352(b) state that the housing assistance payments contract may allow for vacancy payments to the owner extending from the beginning of the first calendar month after the move-out month for a period not exceeding 2 full months following the move-out month. However, the units these three households resided in were not project-based since the developments housing the units did not receive a HUD-approved subsidy layering review and a project-based housing assistance payments contract was not executed for these developments. Therefore, we still considered the payments made for the three households subsequent to the date of death as ineligible. Comment 5 We made changes to finding three to reflect the appropriate overpaid housing assistance that needs to be recovered. Overpaid housing assistance changed from $7,273 to $4,759 based on the $2,514 that was recouped by the Authority. 24 Appendix C FEDERAL REQUIREMENTS AND THE AUTHORITY’S SECTION 8 ADMINISTRATIVE PLAN Finding 1 Section 14-II.C of the Authority’s Section 8 administrative plan states that when the Authority determines that a Section 8 owner has committed program abuse, the Authority may require the owner to repay excess housing assistance. Part B7(a)4 of the tenant-based voucher housing assistance payments contract states that housing assistance shall only be paid to the owner while the family is residing in the owner’s contract unit during the term of the housing assistance payments contract. Part B7(f) of the tenant-based voucher housing assistance payments contract states that if the public housing agency determines that the owner is not entitled to housing assistance payment, the public housing agency, in addition to other remedies, may deduct the amount of overpayment from any amounts due to the owner. Finding 2 HUD’s regulations at 24 CFR 983.351(c) state that the housing assistance payment by the public housing agency to the owner for a project-based contract unit leased to a family is the rent to owner minus the tenant rent (total tenant payment minus the utility allowance). HUD’s regulations at 24 CFR 982.505(b) state that the public housing agency shall make a monthly based housing assistance payment for tenant-based vouchers on behalf of the family that is equal to the lower of (1) the payment standard minus the total tenant payment or (2) the gross rent minus the total tenant payment. Section 14-II.D of the Authority’s Section 8 administrative plan states that the Authority must reimburse a family for any underpayment of housing assistance, regardless of whether the underpayment was the result of staff-caused error or owner program abuse. Finding 3 HUD’s regulations at 24 CFR 982.311(a) states that housing assistance payments are made to the owner in accordance with the terms of the housing assistance payments contract. Housing assistance may only be paid to the owner during the lease term and while the family is residing in the unit. HUD’s regulations at 24 CFR 983.55(b) state that the public housing agency may not enter an agreement or a housing assistance payments contract until HUD or an independent entity 25 approved by HUD has conducted a required subsidy-layering review and determined that project-based voucher assistance is in accordance with HUD subsidy-layering requirements. HUD’s regulations at 24 CFR 983.351(a)(1) state that during the term of the housing assistance payments contract, the public housing agency shall make housing assistance payments to the owner in accordance with the terms of the housing assistance payments contract. The payments shall be made for the months during which a contract unit is leased to and occupied by an eligible family. HUD’s regulations at 24 CFR 983.351(a)(2) state that except for discretionary vacancy payments in accordance with 24 CFR 983.352, the public housing agency may not make any housing assistance payment to the owner for any month after the month when the family moves out of the unit (even if the household goods or property are left in the unit). HUD’s regulations at 24 CFR 983.351(b) state that each month the public housing agency shall make housing assistance payment to the owner for each contract unit that complies with the housing assistance quality standards and is leased to and occupied by an eligible family in accordance with the housing assistance payments contract. HUD’s regulations at 24 CFR 983.352(b)(1) state that at the discretion of the public housing agency, the housing assistance payments contract may provide for vacancy payments to the owner extending from the beginning of the first calendar month after the move-out month for a period not exceeding 2 full months following the move-out month. Section 13-II.E of the Authority’s Section 8 administrative plan states that if the family moves out of the assisted unit, the owner is entitled to keep the housing assistance payment for the month when the family moves out. 26
The Housing Authority of the County of Cook, Chicago, IL, Needs to Improve Its Controls Over Its Administration of Section 8 Housing Assistance Payments to Its Nonprofit Units
Published by the Department of Housing and Urban Development, Office of Inspector General on 2011-02-07.
Below is a raw (and likely hideous) rendition of the original report. (PDF)