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PHA Supervisory Audits

PHA Supervisory Audits. Supervisory QC Reviews. Periodic samples of files Drawn in unbiased manner (leave clear audit trail) Reviewed by supervisor or other qualified person other than the one who did the work Objective: determine compliance with indicator.

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PHA Supervisory Audits

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  1. PHA Supervisory Audits

  2. Supervisory QC Reviews • Periodic samples of files • Drawn in unbiased manner (leave clear audit trail) • Reviewed by supervisor or other qualified person other than the one who did the work • Objective: determine compliance with indicator

  3. 1st 7 SEMAP Indicators*Indicates PHA audit needed Selection from Waiting List* 15 Reasonable Rent* 20 Determination of Adjusted Income* 20 Utility Allowance Schedule 5 HQS Quality Control Inspections* 5 HQS Enforcement* 10 Expanding Housing Opportunities 5

  4. Size of Universe • Determines file sample size • Not the same for each indicator • e.g., # number of admissions vs. number of families assisted

  5. 5 5 + 1 for each 50 (or part of 50) over 50 16 + 1 for each 100 (or part) over 600 30 + 1 for each 200 (or part) over 2000 Audit Sample Selection • 50 or less • 51-600 • 601-2000 • Over 2000

  6. File Sampling • Determine the universe • Determine number of files to be selected for review • Determine “nth” file this represents • Include all staff in sample • FY is period for analysis

  7. Minimum Files Example • Waiting List Selection: • Based on # of new admissions per FY • Example: PHA has admitted 260 families • minimum # of files to audit? • # of files which must meet criteria to receive 15 points? Note: 98% 10 98.8 (10) files 51-600 = 5 + 1 for each 50 (or part of 50) over 50

  8. Random Sampling Example • Universe requirement 260 files • File Sample 10 files • Files to be pulled Every 26th file • If all staff are not represented, select closest file below 26th file

  9. 1. Selection from Waiting List (15/0 points) • Universe • Number of families admitted to program during audit period • Two separate samples drawn from: • Applicant names that reached the top of the waiting list during the audit period • Families admitted to the program during the audit period

  10. 1. Selection from Waiting List (Supervisory Audit) • PHAs must have written selection policies in administrative plan • At least 98% of families must be selected from the waiting list in accordance with the PHA’s policies Page 2-1

  11. 1. Selection from Waiting List • PHA follows policies in selecting families from waiting list • Families met selection criteria that determined their place on waiting list and order of selection

  12. Most Likely Error Points • Get up to date on preferences in 982.207 • Residency preference • Working preference • Singles preference • Preference for persons with disabilities

  13. Policies for Audit File • Example: October FY PHA • Policy changes in last year: • 10/1/XX 10/1/XX-2/28/XX • 3/1/XX 3/1/XX-6/30/XX • 7/1/XX 7/1/XX-9/30/XX

  14. Other Issues • Income targeting • 75% of new admissions in PHA’s FY must be Extremely Low Income Families • ELI = 30% of Area Median • How do you track this?

  15. Other Issues • Does PHA staff understand • Special Admissions 982.203 • Targeted funding • Funding for specified category of waiting list families, such as: • Family Unification • Mainstream for Persons with Disabilities

  16. Getting Proof • Put copy of the top of the WL you pulled from in file • Note why you skipped someone if you did • Note if you did any special admissions • Attach copy of each letter sent

  17. Waiting List Notations • Jones skipped (reason) • Sarazac skipped (reason) • Verona income targeting • Palstrom skipped (reason) • Belle income targeting

  18. 2. Reasonable Rent(20/15/0 points) • Universe • Number of families assisted for PHA FY • Sample drawn from • Number of families assisted for PHA FY

  19. 2. Reasonable Rent (Supervisory Audit) • The PHA must have a reasonable written method to determine • Rent to owner is reasonable based on current rents charged for comparable unassisted units Page 2-16

  20. 2. Reasonable Rent • The method may take into consideration • Location • Size • Type • Quality • Age • Amenities • Housing services • Maintenance • Utilities

  21. 2. Reasonable Rent • PHA must follow its written method • Document determination that the rent to owner is reasonable at required times • Initial leasing of a unit • Any increase in rent to owner • 5% decrease in the FMR in effect 60 days before HAPC anniversary date

  22. Rent Reasonableness • Involves two comparisons between the rent charged for an HCV unit and the rent charged: • For similar units in the private unassisted market • For similar unassisted units on the premises

  23. Documentation • PHAs required to supply documentation about each rent reasonableness determination • Include data on unassisted units compared • Identify who made the rent reasonableness determination and when

  24. Rent Reasonableness Notice PIH 2003-12 • Use of Rent Reasonableness Factors • Notice clarifies that PHAs are NOT required to apply all nine rent reasonableness factors individually to fully comply with the regulation at 24 CFR 982.507(b)

  25. Rent ReasonablenessNotice PIH 2003-12 • Request for Tenancy Approval form: • Item 12a: Owners of projects with >4 units must provide rents on 3 comparable unassisted units on premises • PHAs may use these comparables to determine and document rent reasonableness in same multifamily apartment complex • If complex not substantially assisted, no additional comparables required Page 2-17

  26. Rent Reasonableness Notice PIH 2003-12 • Commonsense approach calls for rent reasonableness determinations that are: • Accurate • Based on comparables • Documented • Reasonable • Consistent Page 2-17

  27. 3. Determination of Adjusted Income (20/15/0 points) • Universe • Number of families assisted for PHA FY • Sample drawn from • Number of families assisted for PHA FY Page 2-44

  28. 3. Determination of Adjusted Income (Supervisory Audit) • At admission and reexamination, the PHA must properly: • Obtain third party verification of income or document why impossible to obtain • Use the verified information • Properly attribute allowances for expenses • Use the appropriate utility allowances Page 2-44

  29. Most Likely Error Points • Market/cash value of assets • Asset income • Training program income • EID for persons with disabilities • Disability assistance & medical expenses • Conflict between utilities in lease and worksheet

  30. Recommended Levels of Verification • Highest – Up-front income verification (UIV) • High – Written 3rd party • Medium – Third party oral • Medium-low – Document review • Low – Tenant declaration

  31. Use of UIV for Verification • UIV is third-party verification • Most preferred form • Meets regulatory requirements • UIV is intended to streamline the verification process • Eliminates the need for written third-party verification in many cases

  32. NEW! HUD Guidance on EIV • HUD webcast 1/16/08 contained revised guidance on use of EIV • Previous guidance is obsolete and has been removed from EIV website • Webcast available at http://www.hud.gov/webcasts/archives/ph.cfm • 4 hours

  33. 4. Utility Allowance Schedule (5 points) • PHA has reviewed utility rate data within prior 12 months • PHA has adjusted schedule if 10%+ change in rate since last utility allowance schedule revision Page 2-54

  34. NOTE! • PHA needs a record of the date each utility rate on each utility allowance is revised Page 2-54

  35. Exception • Utility Allowance • CFR 982.517: PHAs must revise utility allowances whenever there is a utility rate change of 10% or more • PIH 2005-9: PHA experiencing financial difficulties may request a HUD waiver, for good cause

  36. 5. HQS Quality Control Inspections (5/0 points) • Universe • Units under HAPC during last completed FY Page 2-61

  37. 5. HQS Quality Control Inspections (Supervisory Audit) • PHA performs QC inspection of units under contract • Sampling drawn from: • Recently completed inspections • Cross section of neighborhoods • Work of cross section of inspectors Page 2-61

  38. 6. HQS Enforcement (10/0 points) • Universe • Number of failed HQS inspections in last FY • Sample drawn from • Number of failed HQS inspections in last FY Page 2-68

  39. 6. HQS Enforcement (Supervisory Audit) • The PHA must ensure that when a unit fails an HQS inspection • Any life-threatening deficiencies are corrected within 24 hours, and • All other HQS deficiencies are corrected within no more than 30 calendar days or PHA approved extension Page 2-68

  40. 6. HQS Enforcement • If HQS deficiencies are not corrected within the required time frame PHA must: • Stop housing assistance payments, or • Take prompt action to enforce the family obligations

  41. 6. HQS Enforcement • All life threatening fails corrected within 24 hrs • 98% of other fails corrected within 30 days or PHA approved extension • If not, PHA took action • Owner fails: abated HAP • Family fails: enforced family obligations

  42. 7. Expanding Housing Opportunities (5/0 points) A. Written policy to encourage owner participation outside areas of poverty or minority concentration B. Documentation shows PHA followed policy

  43. Expanding Housing Opportunities C. PHA has created a briefing packet to encourage voucher holders to seek these opportunities (e.g. maps, job opportunities, schools and other services in the areas)

  44. Expanding Housing Opportunities D. Information packet has • List of owners willing to lease • Other organizations (housing counseling, advocacy groups, service providers) which assist families in finding units

  45. Expanding Housing Opportunities E. Information packet explains portability and provides list of contacts at neighboring PHAs • Name • Address • Phone

  46. Expanding Housing Opportunities F. PHAs have analyzed: • Difficulties of Voucher holders finding units in these areas • if so, has analyzed • Whether to seek approval of exception payment standards • Sought approval for exception payment standards if needed

  47. Payment Standards(5/0 points) • The PHA must adopt Payment Standards • By unit size • For each FMR area in the PHA jurisdiction • Between 90-110% of the HUD-published FMR • If applicable, for each PHA-designated part of an FMR area Page 2-85

  48. 8. Payment Standards • If any Payment Standard schedule contains a payment standard that is out of range from the appropriate FMR • Field office will assign 0 points for the indicator

  49. 8. Payment Standards • Example: • FMR for 2 bedroom unit $756 • $756 x 1.10 = $831.60 (round down) • $756 x .90 = $680.40 (round up) • To be within range PS can be between: • $681 - $831

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