ADMINISTRATIVE PLAN - San Antonio Housing Authority

Repayment to the PHANeither a family nor an owner is required to repay an overpayment of subsidy if the error orprogram abuse is caused by PHA staff [HCV GB. 22-12].PHA Reimbursement to Family or OwnerThe PHA must reimburse a family for any underpayment of subsidy, regardless of whether theunderpayment was the result of staff-caused error or staff or owner program abuse. Funds for thisreimbursement must come from the PHA’s administrative fee reserves [HCV GB p. 22-12].Prohibited ActivitiesPHA PolicyAny of the following will be considered evidence of program abuse by PHA staff:Failing to comply with any HCV program requirements for personal gainFailing to comply with any HCV program requirements as a result of a conflict ofinterest relationship with any applicant, participant, or ownerSeeking or accepting anything of material value from applicants, participatingfamilies, vendors, owners, contractors, or other persons who provide services ormaterials to the PHADisclosing confidential or proprietary information to outside partiesGaining profit as a result of insider knowledge of PHA activities, policies, orpracticesMisappropriating or misusing Authority fundsDestroying, concealing, removing, or inappropriately using any records related tothe HCV programUnauthorized removal of PHA property, to include files and/or documents..Committing any other corrupt or criminal act in connection with any federalhousing program14-II.E. CRIMINAL PROSECUTIONPHA PolicyWhen the PHA determines that program abuse by an owner, family, or PHA staffmember has occurred and the amount of overpaid subsidy meets or exceeds the thresholdfor prosecution under local or state law, the PHA will refer the matter to the appropriateentity for prosecution. When the amount of overpaid assistance meets or exceeds thefederal threshold, the case will also be referred to the HUD Office of Inspector General(OIG).Other criminal violations related to the HCV program will be referred to the appropriatelocal, state, or federal entity.© Copyright 2008 Nan McKay & Associates, Inc. Revised/Approved 04/08/10 (Eff: 07/01/10)Unlimited copies may be made for internal use.Page 14-10