Review Processes And Common Errors Found
(Excerpts)
USED WITH PERMISSION BY:
CASTERLINE ASSOCIATES PC
VALLEY FORGE, PA
(800)337-5088
www.casterline.net
Review Selection Process
 PHAs are select for review based on a developed risk
list from the following:
 FMC recommended
 FMD recommended
 Field Office recommended
 Sh0rtfall Prevention Team recommended
 Unresolved issues from prior QAD reviews
 Risk list provided to OFO and FO
Issues already identified by all of the above sources
through their involvement with the PHA and VMS data
entry.
Documentation Requirements
§ 982.158 Program accounts and records
(a) The PHA 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. The records must be in the form required by HUD,
including requirements governing computerized or electronic forms of recordkeeping. The PHA must comply with the financial reporting requirements in 24 CFR
part 5, subpart H.
(b) The PHA must furnish to HUD accounts and other records, reports, documents
andinformation, as required by HUD. For provisions on electronic transmission of
required familydata, see 24 CFR part 908.
(c) HUD and the Comptroller General of the United States shall have full and free
access to all PHA offices and facilities, and to all accounts and other records of the
PHA that are pertinent to administration of the program, including the right to
examine or audit the records, and to make copies. The PHA must grant such access
to computerized or other electronic records, and to any computers, equipment or
facilities containing such records, and shall provide any information or assistance
needed to access the records
Documentation Requirements (continued)
 All information must be by ‘voucher type’
 Utilization reports for UML verification
 HAP contracts
 HAP contracts on hold
 HAP termination listing
 Portability reports
 FSS reports
 Any other reports used to capture UML on the VMS
reporting
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Hope VI
Tenant Protection
Documentation Requirements (continued)
 Financial Records – for validation of HAP and other
reported line items (i.e. fraud recovery)
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HAP registers
Check registers
General ledgers
Trial balances
Reconciled bank statements
Voided check registers
Chart of Accounts
FSS Escrow reports
Fraud recovery records
Any other documents off-line or system generated used to
enter VMS data
VMS Review – What to Expect
 QAD compares the data reported in VMS to the source documents
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the PHA used to calculate the data
QAD usually examines summary data from the PHA’s information
system and check it against detailed records
For UML detail, we will need to see HAP registers, tenant listings or
other system reports that sort participants by voucher type
For HAP detail, we most often rely on the general ledger, which
should also be sorted by voucher type (and check these against
bank records)
A reasonable assurance that summary data are accurate will be
made to determine which source documentation will be used
VMS Reviews – What to Expect (continued)
 Mainly focused on uncovering any significant over or
under-reporting
 Any variance of 3% between the reported and validated
Total UML or 3% or $100,000 of the Total HAP or a
reporting error that is a clear violation of regulation or
statute is an automatic finding
 Over-reporting identified in the current funding year may
lead to a funding recapture or offset of future disbursements
 Under-reporting identified in the current funding year most
likely will not result in recalculation of renewal funding, but
corrections to VMS will help ensure accurate future funding
VMS Reviews – What to Expect (continued)
 Reviewers will also check to ensure that:
 UML and HAP are reported in the correct category
according to the definitions in the VMS Users Manual
 Expenses and units are applied to the correct month
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Reported in the month cost incurred, but not until paid
 Port-out admin fees are not included in HAP
 These are administrative expenses not HAP
 Unabsorbed Port-Ins are not included in regular UML
and HAP totals
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These are administrative expenses not HAP
 Voids are properly accounted for
VMS Reviews – What to Expect (continued)
 Reviewers will validate Fraud Recovery
 Ensure appropriate allocation between NRA and UNA
 Reviewers will validate FSS Escrow Forfeitures
 Ensure funds are returned to the program (HAP account) if
not used for other FSS participants
 Reviewers will ensure the PHA has sufficient cash to back the
PHA reported NRA and UNA balances
 Will compare the reconciled bank statements for the last
month reviewed to the PHA VMS reported cash and
investments balances
 Will also ensure that sufficient cash is available to back
reported NRA and UNA balances
VMS Reviews – What to Expect (continued)
 Reviewers will validate Portability Administered (port-
in)
 Generally the PHA management system will produce a
port-in report
 A limited file review will be conducted
 Reviewer will develop a sample from PIC
 On-site will compare PIC data to HAP register or check
register to ensure HAP amount actually paid was
accurate
 No physical files will be requested – unless discrepancy
is noted
Common Reporting Errors
 UML Errors (remember UML is reported as of first day
of the month)
 Including port-in UML as ‘all other vouchers”
 Reporting vouchers under more than one category
 Reporting under incorrect voucher type
 VASH vouchers are reported as VASH regardless of whether tenant
ports out
 Once tenant protected – always tenant protected
 Including vouchers leased after first of the month as being
under lease on first of month
 Including vouchers on hold
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Issued but not under HAP contract
 Note that HAP vouchers in abatement are included
Common Reporting Errors (continued)
 UML (continued)
 Incorrect remaining under lease at end of month
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Should include all vouchers remaining under lease on the last
day of the month
 HAP Errors
 Including port-in voucher HAP as all other HAP expense
 Including port-out administrative fees as HAP expense
 Reporting on the ‘after first of the month HAP’ line item
all HAP paid with mid-month check run
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Rather than just for those vouchers leased after the first of the
month
Common Reporting Errors (continued)
 HAP (continued)
 Reducing HAP expenses by fraud recovery and FSS
escrow forfeitures
 Reporting on a Cash vs. Accrual basis
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Multiple-months of returned portability payments recorded
in one month
Retro-active vouchers
 Reporting HAP under more than one category
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Duplicate HAP reported
Common Reporting Errors (continued)
 Other errors noted
 Reporting 100% of fraud recovery collected
 Reporting total FR receivables as fraud recovery
collected
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Total amount of repayment agreement
 Reporting $0 fraud recovery
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Keeping 100% of the amount collected as UNA without
justification
 Incorrectly reporting cash and investments
 Failing to report NRA and UNA
Tips for Accurate Reporting
REITERATES FMC INSTRUCTIONS
 Know the proper definitions of VMS categories
 Have detailed, written procedures to govern VMS
data collection and reporting
 Use procedures consistently from month to month
 Involve program, Finance, and IT staff in VMS
reporting
 Have summary reports that tie directly to detailed
reports
Tips for Accurate Reporting (continued)
 Document adjustments for retroactive payments, etc.
 Make notes on any uncommon occurrences that
affect VMS data
 Clear audit trail
 Audit yourself regularly to insure participants are
coded correctly and procedures are being followed
 Encourage your software provider to update
software to make VMS reporting easier