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The Authority did not maintain its waiting list information or obtain all the required information from housing applicants in DHCD’s prescribed manner.

The audit found WHA did not properly maintain waiting list information or get required information from applicants seeking housing.

Table of Contents

Overview

The Authority did not maintain permanent, hardcopy program waiting list ledgers. It maintained this information electronically, but it did not seek and obtain a DHCD waiver of the requirement of hardcopy ledgers. Further, the Authority did not always obtain all required information from applicants. If DHCD’s administrative requirements are not followed, tenants could be incorrectly offered housing ahead of other eligible tenants who should have preceded them.

Specifically, in our review of the 10 tenants who had most recently moved in, we noted the following deficiencies with the application process:

  • Three applications were not date- or time-stamped.
  • Three applicants were provided with emergency housing, but emergency applications had not been completed.
  • Three applicants did not have landlord references.
  • One application did not have a control number (a unique number assigned to identify an application).
  • One offer for housing was accepted more than seven days after the written offer of the unit.

Authoritative Guidance

According to 760 CMR 5.16(2), “The LHA shall maintain permanent handwritten ledgers including a master file ledger and waiting list ledgers.”

In addition, 760 CMR 5.05(2) states, “Each application form received by the LHA shall be date and time stamped, and the applicant promptly provided with a . . . control number.”

DHCD’s Standard Application for State-Aided Public Housing states,

If you have selected one of the . . . emergency categories [on the application] . . . you must complete an EMERGENCY APPLICATION in addition to this Standard Application. All emergency applications must be accompanied by third party written documentation.

Further, 760 CMR 5.12(2) states,

The LHA shall require an applicant to provide the names and current addresses of all landlords (or housing providers) for applicant and household members during the period five years prior to application through the date of the final determination.

Finally, 760 CMR 5.10(4)(a) states, “An applicant offered a unit must accept the offer within seven days of the date of the written offer.”

Reasons for Noncompliance

Authority management officials stated that they were not aware they were required to request a DHCD waiver of the requirement of hardcopy waiting lists. They could not explain the other noted deficiencies because the housing application process was the responsibility of a former employee. We did note that the Authority did not have policies, procedures, or monitoring controls in place to ensure that its staff obtained all required information from applicants.

Recommendations

  1. Until it obtains a waiver from DHCD, the Authority should maintain hardcopy program waiting list ledgers.
  2. The Authority should ensure that housing applications are date- and time-stamped; that they include emergency applications when applicable, as well as control numbers and landlord references; and that written offers for housing are accepted within the prescribed timeframe.
  3. The Authority should establish policies, procedures, and monitoring controls over the application process to ensure that all information required during the process is obtained according to DHCD requirements.
  4. The Authority should assign an employee the responsibility of accepting applications and ensuring that each application complies with DHCD regulations.

Auditee's Response

Addressing the specific areas of concern:

  • Leasing staff have been reeducated as to the requirement of date and time stamping each application. This oversight, however, had no bearing on any applicant’s placement on the waiting list.
  • Despite the fact that an emergency application was not completed in a few instances, emergency status was duly noted and all preferences provided as per the regulations. As with the prior finding, the bureaucratic fact that there wasn’t a second application completed had no bearing on the placement on the wait list.
  • Landlord references are at times quite difficult to obtain. In the majority of cases, we are able to procure the landlord reference checks without much problem. There are situations that arise where an applicant provides a listing of their prior landlords, and then we discover that these individuals no longer own the property, their mailing addresses have changed, or we simply cannot contact them. I am sometimes called upon to make a judgment on behalf of an applicant who has done everything correctly only to potentially have the whole process grind to a halt or end because of the landlord check. I am happy to report that we adhere to the requirement of ordering landlord references, but I will not necessarily deny someone housing because we cannot locate prior landlords.
  • The Wellesley Housing Authority maintains a hand written master ledger. . . .
  • Each of our developments possesses unique characteristics and our applicants are equally diverse and varied. In the case of an offer for housing being accepted more than seven (7) days after the written offer, extenuating circumstances may have been present. Some of our developments have limited or no available parking and we are only able to fill the units with those folks who do not drive; other units (particularly elderly units) are difficult to fill if they are on the second floor due to mobility issues. Although we endeavor to adhere to the “7 day rule,” in specific hard to fill circumstances, I will grant leeway.

Auditor's Reply

Based on its response, the Authority is taking some measures to address our concerns in this area. However, we again recommend that the Authority establish a policy documenting the application process and the administrative oversight put in place to ensure that all tenant applications are processed in accordance with DHCD regulations. The Authority should also assign an employee to receive and review tenant applications to ensure that they comply with DHCD regulations. The application process must be transparent. The use of date- and time-stamping establishes a clear order in which tenants should be entered on the Authority’s waiting list. All tenant applications should be clearly marked when they are received and a control number is issued.

Applicants with emergency situations are required to complete emergency applications along with standard applications and provide documentation verifying their homeless status. The emergency application gives the applicant information and guidance that can help with declaring the applicant’s emergency status and identifying documentation necessary to prove the applicant’s homeless status. This documentation, provided with the emergency application, assists the Authority in determining the applicant’s placement on the waiting list.

Landlord references are important in the decision of whether to extend an offer for housing. A reference may provide an indication of an applicant’s previous behavior. When landlord references are difficult to obtain, the Authority should document in the applicant’s file the efforts made to obtain the references and the decisions made regarding the applicant if references are not obtained.

The Authority maintains a handwritten master ledger, but DHCD requires that program waiting lists be kept in handwritten ledgers unless DHCD grants a waiver and allows for an electronic waiting list. The Authority currently maintains an electronic waiting list ledger and did not provide us with a waiver granted by DHCD. Requesting a waiver from DHCD provides an opportunity to evaluate the electronic process to ensure that it meets DHCD’s specifications.

Although applicants may have a difficult decision regarding housing, the Authority should strive to meet the “seven-day rule” to ensure that housing units are filled in a timely manner and not create extended vacancies. When applicants are given additional time to make a decision, the Authority should document in their files the reasons for the extensions.

Date published: May 30, 2018
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