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Administrative Plan 7/1/2025 <br /> <br />Page 14-3 <br />For purposes of this chapter the term error refers to an unintentional error or omission. <br />Program abuse or fraud refers to a single act or pattern of actions that constitute a false <br />statement, omission, or concealment of a substantial fact, made with the intent to deceive <br />or mislead. <br />14-I.B. DETECTING ERRORS AND PROGRAM ABUSE <br />In addition to taking steps to prevent errors and program abuse, the PHA will use a variety of <br />activities to detect errors and program abuse. <br />Quality Control and Analysis of Data <br />Under the Section 8 Management Assessment Program (SEMAP), HUD requires the PHA to <br />review a random sample of tenant records annually to determine if the records conform to <br />program requirements and to conduct quality control inspections of a sample of units to ensure <br />compliance with applicable housing quality standards [24 CFR, Part 985]. (See Chapter 16 for <br />additional information about SEMAP requirements). <br />SAHA Policy <br />In addition to the SEMAP quality control requirements, SAHA will employ a variety of <br />methods to detect errors and program abuse. <br />SAHA routinely will use HUD and other non-HUD sources of up-front income <br />verification. This includes The Work Number and any other private or public <br />databases available to SAHA. <br />At each annual or interim reexamination, current information provided by the <br />family will be compared to information provided at the most recent reexamination <br />to identify inconsistencies and incomplete information. <br />SAHA will compare family-reported income and expenditures to detect possible <br />unreported income. <br />Independent Audits and HUD Monitoring <br />OMB Circular A-133 requires all PHAs that expend $750,000 or more in federal awards <br />annually to have an independent audit (IPA). In addition, HUD conducts periodic on-site and <br />automated monitoring of PHA activities and notifies the PHA of errors and potential cases of <br />program abuse. <br />SAHA Policy <br />SAHA will use the results reported in any IPA or HUD monitoring reports to identify <br />potential program abuses as well as to assess the effectiveness of the SAHA’s error <br />detection and abuse prevention efforts. <br />Individual Reporting of Possible Errors and Program Abuse <br />SAHA Policy <br />SAHA will encourage staff, program participants, and the public to report possible <br />program abuse. <br />EXHIBIT 1