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In addition to the SEMAP quality control requirements, the PHA will employ a variety of <br />methods to detect errors and program abuse. <br />SAHA routinely will use available sources of up-front income verification, <br />including HUD's EIV system, to compare with family-provided information. <br />At each annual reexamination, current information provided by the family will be <br />compared to information provided at the last annual reexamination to identify <br />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 $500,000 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 SAHA activities and notifies the PHA of errors and potential cases of <br />program abuse. <br />SAHA will use the results reported in any IPA or HUD monitoring reports to identify potential <br />program abuses as well as to assess the effectiveness of SAHA's error detection and abuse <br />prevention efforts. <br />Individual Reporting of Possible Errors and Program Abuse <br />SAHA will encourage staff, program participants, and the public to report possible program <br />abuse. <br />14-I.C. INVESTIGATING ERRORS AND PROGRAM ABUSE <br />When SAHA Will Investigate <br />SAHA will review all referrals, specific allegations, complaints, and tips from any source <br />including other agencies, companies, and individuals, to determine if they warrant investigation. <br />In order for SAHA to investigate, the allegation must contain at least one independently- <br />verifiable item of information, such as the name of an employer or the name of an unauthorized <br />household member. <br />SAHA will investigate inconsistent information related to the family that is identified through <br />file reviews and the verification process. <br />Consent to Release of Information [24 CFR 982.516] <br />SAHA may investigate possible instances of error or abuse using all available PHA and public <br />records. If necessary, SAHA will require HCV families to give consent to the release of <br />additional information. <br />Analysis and Findings <br />SAHA will base its evaluation on a preponderance of the evidence collected during its <br />investigation. <br />Preponderance of the evidence is defined as evidence which is of greater weight or more <br />convincing than the evidence which is offered in opposition to it; that is, evidence that as a whole <br />iii29iio Page 14-3 <br />