ADMINISTRATIVE PLAN - San Antonio Housing Authority

PHA PolicyIn addition to the SEMAP quality control requirements, the PHA will employ a variety ofmethods to detect errors and program abuse.The PHA routinely will use available sources of up-front income verification tocompare with family-provided information.At each annual reexamination, current information provided by the family will becompared to information provided during the previous 12 months to identifyinconsistencies and incomplete information.The PHA will compare family-reported income and expenditures to detectpossible unreported income.Credit bureau inquiries may be made (with proper authorization by theparticipant) in the following circumstances:When the PHA receives an allegation wherein unreported income sources aredisclosed.When a participant’s expenditures exceed his/her reported income and noplausible explanation is given.When a participant reports zero income.Independent Audits and HUD MonitoringOMB Circular A-133 requires all PHAs that expend $500,000 or more in federal awardsannually to have an independent audit (IPA). In addition, HUD conducts periodic on-site andautomated monitoring of PHA activities and notifies the PHA of errors and potential cases ofprogram abuse.PHA PolicyThe PHA will use the results reported in any IPA or HUD monitoring reports to identifypotential program abuses as well as to assess the effectiveness of the PHA’s errordetection and abuse prevention efforts.Individual Reporting of Possible Errors and Program AbusePHA PolicyThe PHA will encourage staff, program participants, and the public to report possibleprogram abuse.© Copyright 2008 Nan McKay & Associates, Inc. Revised/Approved 04/08/10 (Eff: 07/01/10)Unlimited copies may be made for internal use.Page 14-3