Office of Public and Indian Housing, 

Washington, DC 

Monitoring of the Community Service and SelfSufficiency Requirement 

Office of Audit, Region 7 

Kansas City, MO 

Audit Report Number: 2015-KC-0001

February 13, 2015
 

To: Unabyrd Wadhams 

Deputy Assistant Secretary, Office of Field Operations, PQ 

Milan Ozdinec 

Deputy Assistant Secretary, Office of Public Housing and Voucher Programs, PE 

DJ LaVoy 

Deputy Assistant Secretary, Office of Real Estate Assessment Center, PX 

 //signed// 

From: Ronald J. Hosking 

 Regional Inspector General for Audit, 7AGA

Subject: HUD Subsidized More Than 106,000 Noncompliant Households

 

Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector 

General’s (OIG) final results of our review of HUD’s monitoring of the community service and 

self-sufficiency requirement. 

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 

913-551-5870. 

 
Highlights 

What We Audited and Why 

We audited the U.S. Department of Housing and Urban Development’s (HUD) monitoring of the 

community service and self-sufficiency requirement (CSSR). We initiated this audit based on 

several media reports of housing authorities not enforcing CSSR or only recently stressing its 

enforcement. This audit report is a follow-up to the audit report we issued in 2008, showing that 

HUD did not have adequate controls to ensure that housing authorities properly administered 

CSSR. Our audit objective was to determine the extent to which HUD subsidized units occupied 

by noncompliant tenants and housing for tenants whose CSSR status was misreported. 

What We Found 

HUD subsidized housing for 106,000 units occupied by noncompliant tenants, out of nearly 

550,000 potentially CSSR-eligible units nationwide. Out of the nearly 740,000 adult tenants 

living in these units, HUD’s system contained incorrect CSSR status codes for 201,000 tenants. 

This deficiency occurred because HUD did not have adequate controls to monitor compliance 

with CSSR. As a result, HUD paid more than $37 million in monthly subsidies for public 

housing units occupied by noncompliant tenants that otherwise could have housed compliant 

households. 

What We Recommend 

We recommend that HUD develop and implement a written monitoring policy for CSSR to 

ensure that public housing authorities comply with the Quality Housing and Work Responsibility 

Act of 1998 so that more than $448.5 million in public housing operating subsidies will be put to 

better use over the next year. We also recommend that HUD (1) create clarifying guidance for 

housing authorities, (2) develop training, (3) apply penalties or sanctions against housing 

authorities that house ineligible households, (4) produce improved monitoring reports for field 

offices, and (5) fix the error codes resulting from Form HUD-50058 submissions. 

Audit Report Number: 2015-KC-0001 

Date: February 13, 2015 

HUD Subsidized More Than 106,000 Noncompliant Households 
2

Table of Contents 

Background and Objective ...................................................................................... 3

Results of Audit ........................................................................................................ 5

Finding: HUD Subsidized More Than 106,000 Noncompliant Households ........... 5

Scope and Methodology ........................................................................................... 9

Internal Controls .................................................................................................... 12

Appendixes .............................................................................................................. 13

A. Schedule of Funds To Be Put to Better Use ............................................................ 13

B. Auditee Comments and OIG’s Evaluation ............................................................. 14

C. Sample Design Table................................................................................................. 19 

D. Criteria ....................................................................................................................... 21 
3

Background and Objective 

The U.S. Department of Housing and Urban Development (HUD) established its public housing 

program to provide decent and safe rental housing for eligible low-income families, the elderly, 

and persons with disabilities. There are approximately 1.2 million households living in public 

housing units, managed by approximately 3,300 public housing authorities. HUD’s Public 

Housing Operating Fund program provides operating subsidies to public housing authorities to 

assist in funding their operating and maintenance expenses. 

The Quality Housing and Work Responsibility Act of 1998, which amended Section 12 of the 

U.S. Housing Act of 1937, established the community service and self-sufficiency requirement 

(CSSR). It is intended to assist adult public housing residents in improving their own economic 

and social well-being and give these residents a greater stake in their communities. The 

requirement allows residents an opportunity to “give something back” to their communities and 

facilitates upward mobility. 

Regulations for the requirement are provided in 24 CFR (Code of Federal Regulations) 960.600-

609. In addition, HUD’s Office of Public and Indian Housing (PIH) Notice PIH-2009-48, issued 

November 25, 2009, helps public housing authorities understand and administer CSSR in 

response to an audit report issued by the Office of Inspector General (OIG) on March 24, 

2008. This Notice was extended by Notice PIH-2011-11 and Notice PIH-2012-13 indefinitely 

until amended, superseded, or rescinded and without substantial change. 

CSSR states that every nonexempt adult resident of public housing must contribute 8 hours of 

community service each month or participate in an economic self-sufficiency program. 

Community service is the performance of voluntary work or duties that are a public benefit and 

serve to improve the quality of life, enhance resident self-sufficiency, or increase resident selfresponsibility in the community. Self-sufficiency programs include programs for job training, 

employment counseling, work placement, basic skills training, and education. 

Residents exempt from the requirement are those who are 

 62 years of age or older; 

 Blind or disabled and who certify that because of this disability, they are unable to comply 

with the service provisions or primary caretakers of such individuals; 

 Engaged in eligible work activities; 

 Exempt from having to engage in a work activity under the State program funded under the 

Social Security Act or a State-administered welfare-to-work program; or 

 Members of a family receiving welfare assistance, benefits, or service under a State welfare 

program. 

At lease execution or reexamination, all adult members (age 18 or older) of a public housing 

resident’s household must provide documentation showing that they qualify for an exemption if 

they claim to be exempt from CSSR. At each annual reexamination, nonexempt tenants must 
4

present documentation of activities performed over the previous 12 months. Documentation will 

include signatures of supervisors, instructors, or counselors certifying the number of hours 

contributed. If during reexamination a tenant is found to be noncompliant, the member and head 

of household will sign an agreement with the public housing authority to make up the deficient 

hours over the next 12-month period, or the lease will be terminated. 

Based on Notice PIH-2009-48, HUD sends field offices a monthly community service 

monitoring report generated by the PIH Information Center (PIC) system. This report alerts field 

offices to potential issues of noncompliance with the requirement. Field offices contact and 

advise those public housing authorities showing noncompliant public housing residents. This 

remote monitoring provides information for onsite reviews and identifies potential issues, 

problems, concerns, and negative trends regarding compliance with CSSR. 

Section 6 of the U.S. Housing Act of 1937 provides sanctions against any public housing 

authority failing to comply substantially with any provision of the Act relating to the public 

housing program. Sanctions include but are not limited to terminating, withholding, or reducing 

assistance payments. 

We issued audit report 2008-KC-0002, HUD Did Not Ensure That Housing Authorities Properly 

Administered the Community Service and Self-Sufficiency Requirement, on March 24, 2008. In 

that audit, we found that HUD did not have adequate controls to ensure that housing authorities 

properly administered CSSR. Specifically, HUD did not have sufficient guidelines, adequate 

data collection and reporting systems, or effective enforcement mechanisms. Of 68 statistically 

selected households, 44 did not comply with CSSR and were, therefore, ineligible for continued 

occupancy. Based on these results, we estimated that housing authorities improperly renewed or 

extended the leases of at least 85,000 ineligible households, costing an estimated $21.5 million in 

monthly operating subsidies. 

In the 2008 report, we recommended that HUD improve controls to ensure that housing 

authorities properly administer CSSR, resulting in more than $257 million put to better use 

annually. We also recommended that HUD require housing authorities to take corrective action 

against the 44 ineligible households identified as part of our statistical sample review. All 

recommendations for that report are closed. 

The audit objective for this current audit was to determine the extent to which HUD subsidized 

units occupied by noncompliant tenants and housing for tenants whose CSSR status was 

misreported. 

 
5

Results of Audit 

Finding: HUD Subsidized More Than 106,000 Noncompliant 

Households 

HUD subsidized housing for 106,000 units occupied by noncompliant tenants, out of nearly 

550,000 potentially CSSR-eligible units nationwide. Out of the nearly 740,000 adult tenants 

living in these units, HUD’s system contained incorrect CSSR status codes for 201,000 tenants. 

This deficiency occurred because HUD did not have adequate controls to monitor compliance 

with CSSR. As a result, HUD paid more than $37 million in monthly subsidies for public 

housing units occupied by noncompliant tenants that otherwise could have housed compliant 

households. 

HUD Subsidized Housing for Improperly Reported and Noncompliant Tenants 

We selected a nationwide statistical sample of 80 households made up of 154 tenants within the 

age range that requires compliance with CSSR. We reviewed housing authority records for each 

of the sample items to determine (1) whether the unit included a tenant allowed to remain in the 

unit despite noncompliance with CSSR and (2) whether the CSSR status of the tenant was 

properly reported. A tenant could be counted as an exception in our sample for either question or 

both questions. 

Noncompliant Tenants 

HUD subsidized 23 households from our sample for which housing authorities improperly 

renewed or extended the leases of noncompliant tenants without entering into a workout 

agreement. Notice PIH-2009-48 requires housing authorities to enter into a written workout 

agreement with noncompliant tenants (see appendix D). 

In one example, HUD subsidized a household from our sample which was made up of tenants 

who were improperly coded as “exempt” because the housing authority implemented its own 

CSSR exemptions that were not provided in HUD’s regulations. The housing authority stated 

that the whole household was exempt because a tenant received food stamps, when the receipt of 

food stamps by a tenant does not automatically exempt an entire household. 

Based on the noncompliant households identified in our sample of 80, we projected the results 

and estimated that housing authorities renewed or extended the leases of at least 106,000 

ineligible households. 

Improperly Reported Tenants 

HUD received incorrect tenant information from public housing authorities about tenant 

compliance with CSSR. Housing authorities continued to code tenants as “pending” when the 

proper code at annual reexamination was “compliant,” “noncompliant,” or “exempt.” In 

addition, housing authorities sometimes coded tenants as “noncompliant” when they had 

adequate employment documentation on file to support an “exempt” code. Further, housing 

authorities coded tenants enrolled in college as “exempt” when the correct code for higher 
6

education is “compliant.” Lastly, noncompliant tenants were sometimes incorrectly coded as 

“exempt.” Therefore, the tenants’ codes did not comply with CSSR in Notice PIH-2009-48 (see 

appendix D). Based on 70 tenants within the sampled households whose CSSR status was 

improperly reported, we projected the results and estimated that 201,000 tenants nationwide were 

improperly reported to HUD. Some of these improperly reported noncompliant tenants are also 

included in the 106,000 units discussed above. 

HUD Had Inadequate Monitoring Controls 

HUD did not have adequate controls for monitoring compliance with CSSR. Specifically, it did 

not have sufficient monitoring guidelines, adequate reporting systems, or effective sanction 

enforcement procedures. 

Insufficient Monitoring Guidelines 

HUD did not have written monitoring policies and procedures in place regarding CSSR. HUD 

conducted a risk assessment each year to determine monitoring at the highest risk housing 

authorities; however, CSSR did not factor into this risk assessment. In addition, HUD sent out a 

letter each year to the field offices, communicating monitoring priorities, but CSSR compliance 

was not included in the priorities. 

HUD headquarters allowed the field offices the flexibility to choose how they monitored CSSR. 

Of the 56 housing authorities reviewed, 11 indicated that HUD conducted reviews or monitoring 

of CSSR at their authority, while 42 indicated that HUD did not, and 3 did not answer or 

answered “unknown.” 

Inadequate Reporting Systems 

HUD did not have an adequate reporting system in place to track compliance and identify 

problems. We reported the same problem in HUD OIG Audit Report 2008-KC-0002, issued 

March 24, 2008, and as a result of that audit, HUD agreed to issue a monthly community service 

monitoring report as noted in Notice PIH-2009-48. However, these reports were last run and 

distributed in December 2012. A Real Estate Assessment Center contractor generated the 

reports, and when the contract expired, HUD decided not to dedicate resources to renew it. 

The community service monitoring reports were not an effective tool for monitoring housing 

authorities’ compliance with CSSR. The purpose of the report was to alert field offices of 

potential CSSR noncompliance issues. However, the report did not include all CSSR-eligible 

tenants. For example, the report did not include tenants who received wages. Notice PIH-2009-

48 encouraged housing authorities to use 30 hours per week as full time for the work exemption. 

Therefore, excluding all tenants who received wages made the report inaccurate. In addition, the 

report excluded welfare recipients, even though receiving food stamps does not qualify tenants 

for an exemption. The report also did not include disabled tenants. This exclusion conflicted 

with the Notice since disabled tenants must certify that because of their disability they are unable 

to perform community service and self-sufficiency activities. 

HUD’s published fatal error codes relating to CSSR on Form HUD-50058 were not correct and 

did not result in accurate CSSR reporting. A Form HUD-50058 fatal error stops the submission 

process for that household. First, the fatal errors make a tenant exempt when the relationship 

code is equal to F = foster child or foster adult. HUD requirements do not exempt all foster 
7

adults. Second, fatal errors make a tenant exempt when the tenant is listed as disabled. All 

disabled adults should not be coded as “exempt.” Only those whose disability makes them 

unable to perform community service and self-sufficiency activities are exempt. However, the 

fatal error codes require housing authorities to code all foster adults and all disabled adults as 

“exempt.” Otherwise, the Form HUD-50058 submission will not be accepted by the system. 

Ineffective Sanction Enforcement 

HUD did not apply sanctions against housing authorities that failed to enforce CSSR compliance. 

The U.S. Housing Act of 1937, as amended, indicates that HUD may terminate, withhold, or 

reduce assistance payments to housing authorities that fail to comply with its requirements. 

However, HUD noted that it usually issued sanctions only for more serious violations. HUD 

lists these sanctions in Notice PIH-2009-48 as penalties/sanctions against housing authorities 

housing ineligible households yet does not enforce them for CSSR noncompliance. 

HUD also noted that some housing authorities wanted to take action, such as eviction, but certain 

jurisdictions made it difficult to evict anyone for noncompliance with CSSR. HUD stated this 

makes it very challenging for them to enforce the requirement. However, HUD must enforce the 

Act by supporting housing authorities that follow CSSR by not renewing the leases of 

noncompliant tenants. 

HUD Subsidized Noncompliant Tenants 

HUD paid more than $37 million in monthly subsidies for public housing units occupied by 

noncompliant tenants that could have otherwise housed compliant tenants. Potential tenants 

were kept on waiting lists, while tenants who were noncompliant with CSSR continued to live in 

subsidized housing. Based on the ineligible 23 households in our sample, we projected the 

results and estimated that HUD provided subsidies of more than $37 million per month for 

ineligible households. If HUD strengthens its controls over CSSR, we estimate that at least $448 

million will be better used to house compliant households over the next year. 

Conclusion 

HUD spent an estimated $37 million each month subsidizing at least 106,000 ineligible 

households. In addition, HUD subsidized housing for 201,000 tenants whose CSSR status was 

improperly reported. The Quality Housing and Work Responsibility Act of 1998, which 

amended Section 12 of the U.S. Housing Act of 1937, established CSSR. It is intended to assist 

adult public housing residents in improving their own economic and social well-being and give 

these residents a greater stake in their communities. This congressionally mandated requirement 

allows residents an opportunity to “give something back” to their communities and facilitates 

upward mobility. If HUD does not strengthen its controls, it will pay at least $448 million over 

the next year in subsidies for public housing units occupied by noncompliant tenants that 

otherwise could house compliant households. 

Recommendations 

We recommend that the Deputy Assistant Secretary for Field Operations 

1A. Develop and implement a written monitoring policy for CSSR to ensure that public 

housing authorities comply with the Quality Housing and Work Responsibility Act 
8

of 1998 so that $448,580,654 in public housing operating subsidies will be put to 

better use. 

We recommend that the Deputy Assistant Secretary for Public Housing and Voucher Programs 

1B. Create clarifying guidance for housing authorities to follow-up with noncompliant 

tenants to address the projected 106,000 ineligible households receiving subsidies 

from HUD and on proper CSSR coding to address the projected 201,000 tenants 

improperly reported to HUD. 

1C. Develop training to assist housing authorities in understanding and administering 

CSSR. 

1D. Apply penalties or sanctions established by the Act against housing authorities that 

house ineligible households. 

We recommend that the Deputy Assistant Secretary for the Real Estate Assessment Center 

1E. Produce the monitoring reports again to assist field offices in monitoring CSSR 

eligibility updating them to include all CSSR-eligible tenants. 

1F. Fix the fatal error codes resulting from the housing authority submissions of Form 

HUD-50058 to allow accurate reporting of foster and disabled adults. 
9

Scope and Methodology 

We performed our audit work between April and December 2014 at our office in St. Louis, MO. 

Our audit period covered July 2012 through June 2014. 

To accomplish our objective, we 

 Reviewed relevant laws, regulations, and HUD guidance; 

 Reviewed HUD monitoring reports and reviews; 

 Interviewed HUD staff to gain an understanding of relevant monitoring controls; 

 Selected and reviewed a statistical sample of households to determine their compliance, 

noncompliance, or exemption from CSSR; and 

 Reviewed CSSR policies for the housing authorities included in our sample. 

We relied in part on data maintained by HUD in its PIC system. Specifically, we relied on the 

system to identify households occupying public housing units during our audit period. Although 

we did not perform a detailed assessment of the reliability of the data, we determined that the 

computer-processed data were sufficiently reliable for our purposes because we corroborated the 

data with documentation provided by housing authorities in our sample. 

Using data from PIC, we identified 547,711 households nationwide that had lived in public 

housing for more than a year and had at least 1 tenant between 19 and 61 years of age as of June 

30, 2014. These households were made up of 739,194 tenants within the age range that requires 

compliance with CSSR. 

We also relied on HUD’s Central Accounting and Program System (HUDCAPS), another 

database maintained by HUD, to assess the impact on Federal dollars. Although we did not 

perform a detailed assessment of the reliability of the data, we did review prior audits and 

assessments from which we determined that the computer-processed data were sufficiently 

reliable for our purposes. In HUDCAPS, we identified the amount of Federal dollars paid to 

each housing authority between July 1, 2013, and June 30, 2014. We identified the number of 

low-rent units at a housing authority by the greater of either the number of active low-rent units 

listed in HUD’s housing authority reports as of August 31, 2014, or the total number of active 

household records reported in HUDCAPS. With this information, we were able to compute the 

amount of the Federal operating subsidy spent per unit per year by each housing authority. 

The projected amount is a conservative estimate due not only to deducting a margin of error, but 

also excluding several housing authorities with atypical data or unusual levels of expense. We 

excluded 5 housing authorities containing 339 units because they had no units listed or HUD did 

not fully fund them. We also did not include housing authorities with atypical funding streams 

and administration. We omitted 142 housing authorities from the audit universe as outliers 

because the Federal subsidy per unit from standard operating funds was unusually low at less 

than $1,000 per year or unusually high at greater than $6,000. These limitations left a total of 
10

2,903 housing authorities, of which 2,883 had households in our audit universe because they 

contained tenants who had to comply with CSSR. 

To accurately project both the number of households and number of tenants affected by CSSR, 

we used a household as a base sampling unit. We stratified households into six groups according 

to the amount of Federal subsidy and four subgroups according to the number of tenants who 

may be required to perform community service based on their age. First, we ranked households 

by subsidy amount and broke them up into six groups according to where their subsidy amount 

fell within the percentile ranking of the universe. Because one housing authority owned 20.7 

percent of the rental units and 27.6 percent of the dollars in this national universe, we needed to 

assign it a separate cost grouping to control statistical variance and avoid unexpected 

overestimates in the statistical projections. Within each cost grouping, we subdivided 

households into four subgroups based on having one, two, three, or multiple (four or more) 

tenants having to comply with CSSR. These two dimensions combine to create 24 total strata (6 

× 4) shown in the sample design table in appendix C. 

Using this stratification scheme, we tested the performance of several counts and sample designs 

using replicated sampling. We selected a statistical sample of 80 households from these strata, 

using the surveyselect procedure in SAS®

. We then used these households for two separate types 

of projections: (1) dollars going to noncompliant households and the number of households 

affected and (2) total number of tenants who were incorrectly coded in PIC for CSSR. 

We contacted the 56 housing authorities where the 80 households lived to obtain documentation 

related to the tenants within the age range that requires compliance with CSSR. When 

applicable, we asked for specific details about household circumstances and any enforcement 

actions taken against the noncompliant households. We evaluated the compliance, exemption, or 

noncompliance of all adult household tenants for the most recent annual recertification during 

our audit period. We also requested each sampled housing authority’s CSSR policies and asked 

whether HUD provided support or monitoring of the policy. 

We projected the sample results of 23 units occupied by noncompliant tenants and 70 miscoded 

tenants. For the first projection, we treated the sample of 80 households as a traditional, 

stratified sample for projecting proportions and counts and for projecting the mean dollars spent 

on households that should have contributed community service. For the second projection, we 

took the 154 tenants within the age range that requires compliance with CSSR and treated this 

larger group as a cluster sample, with each household being a separate cluster. Using these 

clusters, we projected the total number of improperly classified tenants. Because the 

stratification system groups households according to how many tenants are eligible, the differing 

numbers of tenants had no bias. Also, because we reviewed all of the tenants within the age 

range that requires compliance with CSSR, the variance within each cluster was zero, thereby 

allowing for a tight margin of error in a cluster sample of this size. 

We statistically estimated that HUD subsidized housing for 201,000 tenants whose CSSR status 

was improperly reported and 106,000 units occupied by noncompliant tenants. As a result, HUD 

paid more than $37 million in improper operating subsidy payments each month, or more than 

$448 million annually. This estimate does not include offsetting costs for HUD to implement 
11

our recommendations to strengthen monitoring controls because we were not able to reasonably 

estimate these costs. 

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 objective. 
12

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 objective: 

 Controls over monitoring compliance with CSSR. 

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 Deficiencies 

Based on our review, we believe that the following items are significant deficiencies: 

 HUD did not have written CSSR monitoring policies and procedures in place. 

 HUD did not have adequate reporting systems in place to track CSSR compliance and 

identify problems. 

 HUD did not have effective sanction enforcement procedures to ensure that housing 

authorities enforced CSSR. 

 
13

Appendixes 

Appendix A 

Schedule of Funds to Be Put to Better Use 

Recommendation 

number 

Funds to be put 

to better use 1/ 

1A 448,580,654 

Totals 448,580,654

1/ Recommendations that funds be put to better use are estimates of amounts that could be 

used more efficiently if an 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 HUD implements our recommendations, it will ensure that tenants who 

do not perform the required community service are not permitted to continue to reside in 

public housing. Housing authorities will no longer spend HUD’s operating subsidies for 

noncompliant households but will instead spend those funds to house compliant 

households. Our estimate reflects only the initial year of this benefit. These amounts do 

not include potential offsetting costs incurred by HUD to implement our 

recommendations to strengthen monitoring controls. 

 
14

Appendix B 

Auditee Comments and OIG’s Evaluation 

 

Ref to OIG Auditee Comments 

Evaluation 

Comment 1 
15

Appendix B 

Auditee Comments and OIG’s Evaluation 

 

Ref to OIG Auditee Comments 

Evaluation 

Comment 2 

Comment 3 
16

Appendix B 

Auditee Comments and OIG’s Evaluation 

 

Ref to OIG Auditee Comments 

Evaluation 
17

Appendix B 

Auditee Comments and OIG’s Evaluation 

 

Ref to OIG Auditee Comments 

Evaluation 
18

OIG Evaluation of Auditee Comments 

Comment 1 The two different numbers presented in the report represent two separate, but 

sometimes overlapping problems. The first problem is noncompliance, resulting 

in ineligibility to continue living in the unit. Units included in this count may or 

may not have been coded as noncompliant. The second problem is coding errors, 

which is an information issue for HUD and the housing authorities who cannot 

process tenants correctly if they make incorrect compliance determinations. Not 

all of the noncompliant households we found during our audit are also part of the 

improperly reported tenants. We added clarifying language in the audit report. 

Comment 2 We used the local CSSR policies of the sampled public housing authorities when 

we reviewed for employment exemptions, so we did not overstate the degree of 

noncompliance by applying a more rigorous standard. There is a contradiction as 

to whether the CSSR Monitoring Report lists eligible tenants or eligible 

households. In the comments above HUD says “if we provide a report that 

includes any family with wages...” yet the CSSR Monitoring Report says 

“Residents in column G who do not have wages or welfare income listed in 

Section 7 of the Form HUD-50058.” It would not be appropriate to exclude an 

entire household due to wages as each adult must be evaluated for compliance 

individually. In addition, each adult should be evaluated for the 12 month period 

leading up to the reexamination date, whereas the wages listed on the form are 

prospective. Over 40 percent of the noncompliant units we reviewed would have 

been excluded from CSSR monitoring reports because the noncompliant tenants 

had wages or welfare listed on the 50058. These tenants were not exempt because 

some were not employed for enough hours to be exempt under the housing 

authority’s policy, some were currently employed but during the preceding year 

the tenant was not employed, and some received only food stamps which does not 

exempt a tenant from completing community service. Excluding all households 

with wages or welfare from the CSSR monitoring report is not going to be useful 

as it does not show a true picture of the noncompliance regarding CSSR. 

Comment 3 We will work with HUD to reach a management decision as the current response 

does not state when it will fully implement each recommendation. We have 

renumbered our recommendations for the final report. The recommendations 

referred to as 1D, 1E, and 1F in the Auditee Comments have been renumbered to 

1E, 1F, and 1D, respectively, for the final report. 
19

Appendix C 

Sample Design Table 

Strata Annual Federal 

subsidy 

Sample 

households

Population count Sampling

weights Households Members 

0-10pct_1_CSSR 79,065,590.31 4 43,900 43,900 10975.00

0-10pct_2_CSSR 20,908,042.88 2 11,494 22,988 5747.00

0-10pct_3_CSSR 2,828,858.35 2 1,546 4,638 773.00 

0-10pct_Multi_CSSR 723,935.85 2 399 1,673 199.50 

10-30pct_1_CSSR 222,244,938.52 9 83,752 83,752 9305.78

10-30pct_2_CSSR 60,968,348.65 2 23,037 46,074 11518.50

10-30pct_3_CSSR 10,574,911.15 2 3,963 11,889 1981.50

10-30pct_Multi_CSSR 2,790,300.93 2 1,038 4,396 519.00 

30-50pct_1_CSSR 306,665,304.56 10 89,671 89,671 8967.10

30-50pct_2_CSSR 66,008,906.15 2 19,414 38,828 9707.00

30-50pct_3_CSSR 10,773,565.23 2 3,164 9,492 1582.00

30-50pct_Multi_CSSR 2,413,844.46 2 703 2,940 351.50 

50-76pct_1_CSSR 424,478,158.07 12 100,996 100,996 8416.33

50-76pct_2_CSSR 105,624,445.95 2 25,232 50,464 12616.00

50-76pct_3_CSSR 22,122,541.57 2 5,281 15,843 2640.50

50-76pct_Multi_CSSR 5,542,912.70 2 1,322 5,550 661.00 

94-100pct_1_CSSR 82,764,461.16 2 15,597 15,597 7798.50

94-100pct_2_CSSR 19,709,422.61 2 3,732 7,464 1866.00
20

Strata Annual Federal 

subsidy 

Sample 

households

Population count Sampling

weights Households Members 

94-100pct_3_CSSR 3,952,175.77 2 752 2,256 376.00 

94-

100pct_Multi_CSSR 960,419.72 2 182 768 91.00 

NYCHA_1_CSSR 316,711,059.80 7 64,480 64,480 9211.43

NYCHA_2_CSSR 163,620,949.51 2 33,312 66,624 16656.00

NYCHA_3_CSSR 54,171,933.60 2 11,029 33,087 5514.50

NYCHA_Multi_CSSR 18,247,233.05 2 3,715 15,824 1857.50

Totals 2,003,872,260.57 80 547,711 739,194 

Sample selection is explained in the Scope and Methodology section. 

 
21

Appendix D 

Criteria 

HUD Notice PIH-2009-48 

Community service volunteer work and economic self-sufficiency requirements mandate 

that each nonexempt adult household member(18 years or older) shall either contribute 8 

hours per month of community service within his or her community, or participate in an 

economic self-sufficiency program for 8 hours per month. The requirements can also be 

met by a combination of 8 hours of community service and participation in an economic 

self-sufficiency program. At least 8 hours of activity must be performed each month. An 

individual may not skip a month and then double up the following month, unless special 

circumstances warrant it. The public housing authority will determine whether to permit 

a deviation from the schedule. 

Housing authorities develop a local policy for administration of the CSSR for public 

housing residents within their Admissions and Continued Occupancy Policies (ACOP). 

Elements of the CSSR policy include, but are not limited to, the housing authority’s 

responsibility to administer the requirement, eligible and non-eligible activities, 

exemptions from the requirement, and compliance review standards. 

The ACOP presents how the housing authority determines if an individual is exempt 

from the CSSR and the documentation needed to support the exemption. Exemptions for 

adult residents unable to participate include persons who are 62 years or older; blind or 

disabled who certify that because of this disability, they are unable to comply with the 

service provisions or is a primary caretaker of such individual; engaged in work 

activities; able to meet requirements under a State program funded under part A of title 

IV of the Social Security Act or under any welfare program of the State in which the 

authority is located; or a member of the family receiving assistance, benefits, or services 

under a State program funded under part A of title IV of the Social Security Act or under 

any welfare program of the State in which the authority is located. 

Authorities are encouraged to use 30 hours per week as the minimum number of hours 

for a work activity. Housing authorities must describe in its policy the process to 

determine which tenants are exempt from the requirement, as well as the process for 

determining any changes to the exempt status of the tenant. Housing authorities provide 

the household a copy of the policy at initial application and secure certification of receipt. 

The housing authority makes the final determination whether to grant an exemption from 

the CSSR. 

At lease execution or reexamination, all adult members (18 or older) of a household must 

provide documentation that they qualify for an exemption if they claim to be exempt 

from the CSSR. Nonexempt members must present documentation of the community 

service and self-sufficiency activities performed over the previous year. 
22

If during reexamination a tenant is found to be noncompliant, then a written notice from 

the housing authority to the tenant is provided. It states what the non-compliance with 

CSSR is, states that lease renewal is contingent upon compliance or execution of a 

written work-out agreement or that the noncompliant tenant must move out, that the 

tenant may request a grievance hearing on the housing authorities determination, and that 

the tenant may exercise any available judicial remedy. The tenant and the head of 

household sign a work-out agreement with the housing authority to make up the deficient 

hours over the next year or the lease will be terminated. 

Section 6(j)(4)(A) of the United States Housing Act of 1937 provides sanctions against 

any housing authority failing to comply substantially with any provision of the Act 

relating to the public housing program. Sanctions include, but are not limited to, 

terminating, withholding, or reducing assistance payments. These sanctions are 

applicable to housing authorities failing to substantially comply with the CSSR 

requirement.