oversight

Brown County Housing Authority, Green Bay, WI, Did Not Always Ensure That Its Section 8 Housing Choice Voucher Program Files Complied With HUD's and Its Own Requirements

Published by the Department of Housing and Urban Development, Office of Inspector General on 2015-08-28.

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

      Brown County Housing Authority,
              Green Bay, WI
          Section 8 Housing Choice Voucher Program




Office of Audit, Region 5       Audit Report Number: 2015-CH-1003
Chicago, IL                                         August 28, 2015
To:            John Finger, Program Center Coordinator, 5IPH

               //signed//
From:          Kelly Anderson, Regional Inspector General for Audit, Chicago Region, 5AGA
Subject:       Brown County Housing Authority, Green Bay, WI, Did Not Always Ensure That
               Its Section 8 Housing Choice Voucher Program Files Complied With HUD’s and
               Its Own Requirements


Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of Brown County Housing Authority’s Section 8
Housing Choice Voucher program.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG Web site. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at
(312) 353-7832.
                          Audit Report Number: 2015-CH-1003
                          Date: August 28, 2015

                          Brown County Housing Authority, Green Bay, WI, Did Not Always Ensure
                          That Its Section 8 Housing Choice Voucher Program Files Complied With
                          HUD’s and Its Own Requirements



Highlights

What We Audited and Why
We audited the Brown County Housing Authority’s Section 8 Housing Choice Voucher program
based on our analysis of risk factors related to the public housing agencies in Region 5’s
jurisdiction1 and the activities included in our fiscal year 2015 annual audit plan. Our audit
objectives were to determine whether the Authority (1) appropriately calculated housing
assistance payments and (2) maintained required eligibility documentation to support the
admission and continued occupancy of its program households.

What We Found
The Authority did not always ensure that its program files complied with the U.S. Department of
Housing and Urban Development’s (HUD) and its own policies. Specifically, it did not ensure
that its contractor (1) correctly calculated housing assistance payments and (2) maintained
required household eligibility documentation. As a result of these weaknesses, HUD and the
Authority lacked assurance that program funds were used appropriately.

What We Recommend
We recommend that the program center coordinator of HUD’s Milwaukee public housing
program center require the Authority to (1) reimburse its program more than $5,300 from non-
Federal funds for the ineligible housing assistance payments, (2) support or reimburse its
program nearly $49,000 from non-Federal funds for the unsupported payments, (3) reimburse its
households more than $2,400 for the underpayment of housing assistance, and (4) implement
adequate procedures and controls to address the issues cited in this audit report.




1
    Region 5 includes the States of Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin.
Table of Contents
Background and Objectives ....................................................................................3

Results of Audit ........................................................................................................4
         Finding: The Authority Did Not Always Ensure That Its Program Files Complied
         With HUD’s Requirements and Its Own Policies .......................................................... 4

Scope and Methodology ...........................................................................................8

Internal Controls ....................................................................................................10

Appendixes ..............................................................................................................11
         A. Schedule of Questioned Costs and Funds To Be Put to Better Use ...................... 11

         B. Auditee Comments and OIG’s Evaluation ............................................................. 12

         C. Federal and Authority Requirements ..................................................................... 17




                                                            2
Background and Objectives
Brown County Housing Authority is a public housing agency created by the State of Wisconsin
to provide decent, safe, and sanitary housing for low-income households. The Authority is
governed by a five-member board of commissioners appointed by the mayor. The board’s
responsibilities include performing the duties and functions required by the Authority’s bylaws
and other rules and regulations of the Authority. According to its bylaws, the secretary of the
board will be the Authority’s executive director and is responsible for managing the Authority’s
housing programs.

On December 1, 2009, the Authority entered into a contract with Integrated Community
Solutions for the administration of its Section 8 Housing Choice Voucher program funded by the
U.S. Department of Housing and Urban Development (HUD). On March 18, 2013, the
Authority and its contractor signed an agreement to extend the contract through December 31,
2015. Under the new contract, the contractor was required to prepare an annual program budget
for the Authority’s review and approval. The Authority would reimburse the contractor for
program expenditures that complied with the approved budget.

The program provides assistance to low- and moderate-income individuals seeking decent, safe, and
sanitary housing by subsidizing rents with owners of existing private housing. As of February 23,
2015, the Authority had 3,401 units under contract and was authorized to receive more than $15
million in program funds.

Our objectives were to determine whether the Authority (1) correctly calculated housing
assistance payments and (2) maintained required eligibility documentation to support the
admission and continued occupancy of its program households.




                                                3
Results of Audit

Finding: The Authority Did Not Always Ensure That Its Program
Files Complied With HUD’s Requirements and Its Own Policies
The Authority did not always ensure that its contractor (1) correctly calculated housing
assistance payments and (2) maintained required eligibility documentation. The weaknesses
occurred because the Authority and its contractor lacked a sufficient understanding of program
requirements. In addition, the Authority lacked adequate procedures and controls for monitoring
its contractor for compliance with program requirements. As a result, the Authority overpaid
more than $1,700 and underpaid more than $2,400 in housing assistance. Further, it was unable
to support more than $45,000 in payments of housing assistance.
Housing Assistance Payments Were Miscalculated
We reviewed 602 statistically selected3 certifications for 60 of the Authority’s program household
files for the period December 2012 through November 2014. Our review was limited to the
information maintained by the contractor in the household files.
For the 60 certifications, 25 (42 percent) had incorrectly calculated housing assistance. The 25
certifications contained 1 or more of the following deficiencies:

        15 certifications had incorrect utility allowances,
        7 certifications had income incorrectly calculated,
        3 certifications had incorrect asset calculations,
        3 certifications had incorrect payment standards,
        2 certifications had incorrect medical expenses, and
        1 certification had incorrect minimum rent.

In addition, of the 60 certifications reviewed, 24 contained errors that had no impact on the
housing assistance calculations. These errors included incorrect utility allowances, payment
standards, asset calculations, income calculations, and medical expenses.

As a result of the Authority’s calculation errors, it overpaid $1,709 and underpaid $2,429 in
housing assistance. In addition, it was unable to support its calculations of housing assistance for
two households, resulting in $8,178 in unsupported payments of housing assistance.




2
  One household had two statistically selected monthly housing assistance payments. However, the housing
assistance payment for both months selected was calculated with one certification.
3
  Our methodology for the statistical sample is explained in the Scope and Methodology section of this audit report.


                                                          4
Because the housing assistance was either incorrectly calculated or unsupported, the Authority
inappropriately received $4,341 ($1,293 + $2,327 + $721) in administrative fees.
The Authority Lacked Documentation To Support Households’ Eligibility
We reviewed 60 of the Authority’s program household files to determine whether it maintained
the required documentation to support the households’ eligibility for the program.4 Of the 60
household files reviewed, 11 (18 percent) were missing 1 or more documents needed to
determine household eligibility. The 11 household files were missing the following eligibility
documentation:

          4 files were missing copies of the original household applications,
          4 files were missing requests for tenancy approval,
          3 files were missing full support for household members,
          2 files were missing citizenship declarations,
          2 files were missing landlord ownership documents,
          2 files were missing signed lead-based paint disclosure forms for units built before 1978,
          1 file was missing a Social Security number verification,
          1 file was missing an executed lease, and
          1 file was missing an executed housing assistance payments contract.

Along with its comments, the Authority was able to provide copies of unsupported eligibility
documentation. However, 10 of the 60 household files were still missing 1 or more of the
required eligibility documents as of August 12, 2015. For each household file reviewed, the
table below shows the number of documents originally unsupported, documents provided with
the Authority’s comments, and documents that remained unsupported.


                                                  Originally   Provided with    Remaining
                          Document               unsupported    Comments       unsupported
               Original applications                4              0              4
               Requests for tenancy approval        4              0              4

               Full support for household           3              1              2
               members
               Citizenship declarations             2              0              2

               Landlord ownership documents         2              0              2
               Lead-based paint certifications      2              0              2
               Social Security number               1              1              0

               Executed lease                       1              0              1




4
    See appendix C for criteria.

                                                        5
          Housing assistance payments
          contract                            1               0                1

                      Totals                  20              2                18



Because the 10 household files were missing required eligibility documentation, HUD and the
Authority lacked assurance that the households were eligible for the program. As a result,
$36,935 in housing assistance was unsupported. The Authority inappropriately received $2,726
in administrative fees for the households with missing eligibility documentation.
The Authority Lacked a Sufficient Understanding of Program Requirements
The Authority and its contractor lacked a sufficient understanding of program requirements. For
example, according to HUD’s requirement and the Authority’s administrative plan, an allowance
for air conditioning must be provided when most housing units on the market have central air
conditioning or wired for tenant-installed air conditioners. However, according to the
contractor’s programs leader, his understanding of the requirement was that the allowance for air
conditioning should be provided only when a unit had central air conditioning. The Authority’s
housing administrator agreed with the contractor’s programs leader and stated that she was not
aware that the allowance applied to units with portable air conditioners. She expressed concern
regarding the difficulty of having to support and maintain accurate records of the program units
with portable air conditioners.

In addition, the Authority lacked adequate procedures and controls for monitoring its contractor
for compliance with program requirements. The Authority’s housing administrator generally (1)
performed quarterly quality control reviews of the contractor’s management of the Authority’s
Section 8 program files and (2) communicated the results of these reviews with the contractor.
However, she did not follow up with the contractor to ensure that the program files with housing
assistance payment errors or missing eligibility documents had been corrected. Further, in July
2012, when the contractor changed its method of record retention from hardcopy household files
to electronic files, some of the documents were incorrectly scanned or purged. However, the
Authority did not ensure that its contractor corrected the files that were missing required
documents.
Conclusion
The weaknesses described above occurred because the Authority and its contractor lacked a
sufficient understanding of program requirements. In addition, the Authority lacked adequate
procedures and controls for monitoring its contractor for compliance with program requirements.
As a result, the Authority overpaid $1,709 and underpaid $2,429 in housing assistance. In
addition, it had unsupported payments of $45,113 ($8,178 + $36,935) due to unsupported
housing assistance calculations and missing eligibility documentation.
In accordance with 24 CFR (Code of Federal Regulations) 982.152(d), HUD is permitted to
reduce or offset any program administrative fees paid to a public housing agency if it fails to
perform its administrative responsibilities correctly or adequately under the program. The
Authority inappropriately received $7,067 ($1,293 + $2,327 + $721 + $2,726) in program

                                                   6
administrative fees related to incorrectly calculated housing assistance payments for the 25
program households, unsupported calculations of housing assistance for 2 households, and 10
program households with missing eligibility documentation.
Recommendations
We recommend that the program center coordinator of HUD’s Milwaukee public housing
program center require the Authority to
     1A. Reimburse its program $5,329 from non-Federal funds ($1,709 in housing assistance
         payments + $1,293 in associated administrative fees for overpayments + $2,327 in
         associated administrative fees for underpayments) for the inappropriate payments of
         housing assistance cited in the finding.

     1B. Reimburse the appropriate households $2,429 from program funds for the
         underpayment of housing assistance due to calculation errors.

     1C. Support or reimburse its program $48,560 from non-Federal funds ($8,178 + $36,935
         in housing assistance payments + $721 in administrative fees for the unsupported
         payments + $2,726 in associated administrative fees for the missing eligibility
         documentation) for the unsupported housing assistance payment calculations and
         missing eligibility documentation.

     1D. Implement adequate quality control procedures to ensure that its contractor (1)
         correctly calculates housing assistance payments, (2) obtains and maintains the
         required eligibility documentation, and (3) complies with the HUD requirements and
         the Authority’s administrative plan when determining utility allowances for air
         conditioning.

     1E. Implement adequate procedures and controls to ensure that its housing administrator’s
         quality control process includes but is not limited to (1) seeking corrective actions
         from its contractor when file deficiencies are discovered and (2) obtaining and
         maintaining documentation to support the implementation of the corrective actions.




                                               7
Scope and Methodology
We performed our onsite audit work between January and May 2015 at the Authority’s
contractor’s office located at 2605 South Oneida Street, Suite 106, Green Bay, WI. The audit
covered the period December 1, 2012, through November 30, 2014, but was expanded as
determined necessary.

To accomplish our objectives, we reviewed the following:
        HUD’s regulations at 24 CFR Parts 5 and 982, HUD’s Office of Public and Indian
         Housing notices, and HUD’s Guidebook 7420.10G.

        The Authority’s program administrative plan effective during the audit period,
         accounting records, bank statements, general ledger, 5-year and annual plans, annual
         audited financial statements, computerized databases, policies and procedures, contracts
         with its contractor Integrated Community Solutions, board meeting minutes,
         organizational charts, and program annual contributions contract.

        HUD’s files for the Authority.

We also interviewed the Authority’s and the contractor’s employees and HUD staff.
Finding 1

We statistically selected a stratified random sample of 90 housing assistance payments from the
Authority’s 55,352 monthly disbursements to landlords from December 2012 through November
2014 (24 months). The 90 monthly payments were for 88 households.5 We reviewed the first
616 statistically selected housing assistance payments for 60 households to determine whether the
Authority or its contractor correctly calculated housing assistance and utility allowance payments
and maintained the required documentation to support the households’ admission to the program
and continued occupancy. Although the number of errors (42 percent) was high, the dollar value
of the errors was low. Therefore, we discontinued our review of the Authority’s housing
assistance payments calculations.
The calculation of administrative fees was based on HUD’s administrative fee per household per
month to the Authority. The fees were considered inappropriately received for each month in




5
  One of the households reviewed had two statistically selected monthly housing assistance payments. However, the
housing assistance payment for both months was calculated with one certification. In addition, another household
had two monthly housing assistance payments selected that occurred during different certifications.
6
  The 61 monthly housing assistance payments were from the 60 household certifications, which represented 60
households.

                                                        8
which the housing assistance was incorrectly paid and household eligibility was unsupported.
We limited the inappropriate administrative fees to the amounts of housing assistance payment
calculation errors for the household files that had administrative fees exceeding the housing
assistance payment errors.
We relied in part on data maintained by the Authority and its contractor. Although we did not
perform a detailed assessment of the reliability of the data, we performed a minimal level of
testing and found the data to be adequately reliable for our purposes. We provided our audit
results and supporting schedules to the program center coordinator of HUD’s Milwaukee public
housing program center and the Authority’s housing administrator during the audit.
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, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




                                                9
Internal Controls
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the 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 objectives:

   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 or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.
Significant Deficiency
Based on our review, we believe that the following item is a significant deficiency:

   The Authority and its contractor lacked a sufficient understanding of program requirements.
    In addition, the Authority lacked adequate procedures and controls for monitoring its
    contractor for compliance with program requirements (see finding).




                                                  10
Appendixes
                                        Appendix A
           Schedule of Questioned Costs and Funds To Be Put to Better Use
     Recommendation                                                  Funds to be put
         number              Ineligible 1/      Unsupported 2/       to better use 3/
           1A                 $5,329
             1B                                                          $2,429
             1C                                    $48,560

            Total             $5,329               $48,560               $2,429


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 the 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/   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. In this instance, if the Authority implements our
     recommendations, it will ensure that households do not overpay their portion of rent for
     the underpayment of housing assistance due to calculation errors by the
     contractor. Instead, the Authority will spend those funds in accordance with HUD’s
     requirements and its own program administrative plan. Once the Authority successfully
     improves its oversight of the contractor, this will be a recurring benefit.




                                              11
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 1


Comment 2




                               12
Ref to OIG   Auditee Comments
Evaluation




Comment 3




Comment 4




Comment 5


Comment 6




Comment 7




                            13
Ref to OIG   Auditee Comments
Evaluation




Comment 8




Comment 9

Comment 10

Comment 8




                            14
                         OIG Evaluation of Auditee Comments


Comment 1   According to the Authority, the county executive appoints the board of
            commissioners. According to the Wisconsin Statute, General Municipality Law,
            66.40(5) the mayor should, with confirmation of the council, appoint 5 persons as
            commissioners of the Authority. The Authority did not provide documentation to
            support its assertion that the county executive appoints the board of
            commissioners. Therefore, we did not modify the report.
Comment 2   The Authority contends that 15 errors were attributable to the utility allowance
            calculations. We agree, as stated in finding 1 of the audit report. In addressing
            the audit report’s recommendations, the Authority should work with HUD to
            ensure that it fully addresses the issues cited in this audit report.
Comment 3   The Authority contends that the incorrect income calculations that were identified
            in the audit report were due to human error. Although income calculation errors
            occurred during the recertification process, the Authority’s quality control process
            was not sufficient to mitigate or reduce the amount of errors. As mentioned in the
            audit report, the Authority did not ensure that its contractor corrected the program
            files with housing assistance payment errors. When errors in the calculation of
            housing assistance payments occur; HUD and the Authority lack assurance that
            Federal funds are being used efficiently and effectively. We commend the
            Authority for working with its contractor to ensure that adequate training is
            provided to the staff completing re-certifications.
Comment 4   The Authority contends that the errors regarding missing documentation resulted
            from improper filing and erroneously discarding items when the files were
            purged. We commend the Authority for identifying this weakness with regard to
            documentation maintenance and its intent to provide training on HUD’s
            documentation retention requirements. In addressing the audit report’s
            recommendations, the Authority should work with HUD to ensure that it fully
            addresses the issues cited in this audit report.
Comment 5   The Authority provided additional eligibility documentation with its comments to
            this report. We reviewed the documentation and reduced the amount of
            unsupported costs from $49,583 to $48,560. The Authority should provide
            subsequent documentation to HUD to address the recommendations in this audit
            report.
Comment 6   The Authority contends that all of the aspects of its program were without issue.
            When completing a survey, we review small aspects of many areas of the
            program. During our review, we did not identify significant deficiencies in the
            areas of income discrepancy, deceased households, multi-subsidy, waiting list,
            portability, and the Family Self-Sufficiency program. While we tested these
            items initially, our testing was not sufficient to say that no errors occurred, only


                                               15
              that our review did not determine that there were significant errors in the items we
              reviewed.
Comment 7     The Authority contends that the audit report failed to mention that the audit ended
              early at the request of the onsite OIG auditor. The time it takes to complete a
              HUD OIG audit varies. In this case, the audit started in January 2015 and the
              audit field work was completed in May 2015. This is within normal timeframes
              for an audit. Further, as mentioned in the Authority’s comment 2 and in the body
              of the audit report, most of the housing assistance payments errors were the result
              of incorrect utility allowances and income calculations. In addition, although the
              dollar value of the errors was low, the error rate for the housing assistance
              calculations was high (42 percent). Therefore, we recommended that the
              Authority implement adequate quality control procedures to ensure that its
              contractor (1) correctly calculates housing assistance payments and (2) complies
              with the HUD requirements and the Authority’s administrative plan when
              determining utility allowances for air conditioning.
Comment 8     The Authority contends that it will implement a system to follow up with its
              contractor to ensure corrections are made when identified through its quality
              control reviews. In addressing the audit report’s recommendations, the Authority
              should provide copies of its newly created procedures to HUD to ensure that they
              are appropriate and fully implemented to address the issues cited in this audit
              report.
Comment 9     The Authority stated that it would continue to provide documentation to support
              housing assistance payments and household eligibility. The Authority should
              provide subsequent documentation to HUD in addressing the recommendations in
              this audit report.
Comment 10 We commend the Authority for planning to enhance its quality control process.
           In addressing the audit report’s recommendations, the Authority should provide
           copies of its newly created procedures to HUD to ensure that they fully address
           the issues cited in this audit report.




                                                16
Appendix C
                             Federal and Authority Requirements

Regulations at 24 CFR 5.210(a) state that applicants for and participants in covered HUD
programs are required to disclose and submit documentation to verify their Social Security
numbers.

Regulations at 24 CFR 5.240(c) state that the responsible entity must verify the accuracy of the
income information received from the family and change the amount of the total tenant payment,
tenant rent, or program housing assistance payment or terminate assistance, as appropriate, based
on such information.

Regulations at 24 CFR 5.508(b)(1) state that for U.S. citizens or U.S. nationals, the evidence of
citizenship or eligible immigration status consists of a signed declaration of U.S. citizenship or
U.S. nationality. The responsible entity may request verification of the declaration by requiring
presentation of a U.S. passport or other appropriate documentation.

Regulations at 24 CFR 5.603(b) state that medical expenses, including medical insurance
premiums, are anticipated expenses during the period for which annual income is computed that
are not covered by insurance.

Regulations at 24 CFR 982.54(1) state that the public housing agency must adopt a written
administrative plan that establishes local policies for the administration of the program in
accordance with HUD requirements. Paragraph (b) states that the administrative plan must be in
accordance with HUD regulations and requirements. Paragraph (c) states that the public housing
agency must administer the program in accordance with the agency’s administrative plan.

Regulations at 24 CFR 982.152(d) state that HUD may reduce or offset any administrative fee to
the public housing agency, in the amount determined by HUD, if the agency fails to perform
agency administrative responsibilities correctly or adequately under the program.

Regulations at 24 CFR 982.158(e) state that during the term of each assisted lease and for at least
3 years thereafter, the agency must keep (1) a copy of the executed lease, (2) the housing
assistance payments contract, and (3) the application from the family. Paragraph (f) states that
the agency must keep the following records for at least 3 years: lead-based paint records and
records to document the basis for the determination that the rent to the owner is a reasonable rent
(initially and during the term of a housing assistance payments contract).

Regulations at 24 CFR 982.302(c) state that the family must submit to the agency a request for
approval of the tenancy and a copy of the lease, including the HUD-prescribed tenancy
addendum.

Regulations at 24 CFR 982.402(a)(1) state that the public housing agency must establish subsidy
standards that determine the number of bedrooms needed for families of different sizes and

                                                 17
compositions. Paragraph (b)(1) states that the subsidy standards must provide for the smallest
number of bedrooms needed to house a family without overcrowding. Paragraph (3) states that
the subsidy standards must be applied consistently for all families of like size and composition.

Regulations at 24 CFR 982.505(c)(3) state that if the amount on the payment standard schedule
is decreased during the term of the housing assistance payments contract, the lower payment
standard amount generally must be used to calculate the monthly housing assistance payment for
the family beginning on the effective date of the family’s second regular reexamination
following the effective date of the decrease in the payment standard amount.

HUD’s regulations at 24 CFR 982.517(2) state that the public housing agency must maintain a
utility allowance schedule for all tenant-paid utilities (except telephone), the cost of tenant-
supplied refrigerators and ranges, and other tenant-paid housing services. Paragraph (b)(2)(ii)
states that the public housing agency must provide a utility allowance for tenant-paid air
conditioning costs if most housing units in the market provide central air conditioning or there is
appropriate wiring for tenant-installed air conditioners.

Section 3-I.M. of the Authority’s administrative plan states that a family’s request for a live-in
aide must be made in writing. For continued approval, the family must submit a new, written
request, subject to the housing authority verification, at each annual reexamination. In addition,
the family and live-in aide will be required to submit a certification stating that the live-in aide is
(1) not obligated for the support of the person(s) needing the care and (2) would not be living in
the unit except to provide the necessary supportive services.

Section 5-II.C of the Authority’s administrative plan states that in determining family unit size
for a particular family, the housing authority may grant an exception to its established subsidy
standards if the housing authority determines that the exception is justified by the age, sex,
health, handicap, or relationship of family members or other personal circumstances. Reasons
may include but are not limited to

          A need for an additional bedroom for medical equipment or
          A need for a separate bedroom for reasons related to a family member’s disability,
           medical, or health condition.

Section 6.I.G of the Authority’s administrative plan states that in cases in which a trust is not
revocable by or under the control of any member of a family, the value of the trust fund is not
considered an asset. However, any income distributed to the family from such a trust is counted
as a periodic payment or a lump-sum receipt as appropriate.

Section 6.III.A of the Authority’s administrative plan states that the minimum rent is $50.

Section 7.III.D of the Authority’s administrative plan states that if child support payments are
made through a State or local entity, the housing authority will request a record of payment for
the past 12 months.


                                                   18
Section 16-II.C of the Authority’s administrative plan states that an allowance for air
conditioning must be provided when the majority of housing units in the market have central air
conditioning or are wired for tenant-installed air conditioners. Further, the Authority has
included an allowance for air conditioning in its schedule. Central air conditioning or a portable
air conditioner must be present in a unit before the Authority will apply this allowance to a
family’s rent and subsidy calculations.

Exhibit 6-2 of the Authority’s administrative plan states that food stamps are excluded from
annual income.




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