Tip #2: Document selection of file samples.
Remember, your PHA submits a certification to HUD covering the first eight SEMAP indicators. For most of these indicators, your certification is based on a review of randomly selected files. The file reviews determine how many points your agency earns for each of the indicators, and the certification is subject to review by your auditor and by HUD.
Before selecting individual case files, you must determine how many files need to be reviewed for each indicator. The sample size varies by indicator and is dictated by HUD regulations.
For example, two separate file samples are required for Indicator 1, Selection from the Waiting List. The first sample is drawn from all families who reached the top of the waiting list during the fiscal year, including families who were not admitted to the program. The second sample is drawn from families who were admitted to the program. The number of files reviewed is determined by applying the HUD formula to the number of files in each of these two groups.
The HUD formula for determining the number of
files to be reviewed by sample size can be found at
24 CFR 985.2, under the definition of
PHA's quality control sample.
Once you have determined how many files must be reviewed for each indicator or sub-indicator, you must ensure that sample files are selected randomly. For example, if you determine that 200 families reached the top of the waiting list last year, the HUD formula would require you to review eight files. The eight files must be selected randomly from the list of 200. To ensure randomness, you might opt to select every twenty-fifth file, or use an online random selection tool such as Random.org.
Regardless of the method used to select the random sample, it's very important to document how the selections were made. The agency needs to leave a clear audit trail in order to prove that the selection was truly random. In other words, you need to be able to prove that the reviewer did not pick and choose in order to review only correct files.
Documentation of sample selection should include copies of reports or lists used for selection, as well as screen shots or calculation methods used to pick individual files. This documentation should be signed and dated by the responsible staff member.
Next: How to maximize your agency's HCV performance rating: Tip #3
NMA senior consultant Teri Robertson is nationally recognized as a leading expert in HCV and public housing rent calculation, including HUD RIM review requirements. She specializes in helping agencies improve program utilization to maximize funding. She has previously written for the NMA blog about HCV administrative fees.
