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<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 the 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 SAn <br />and abuse prevention efforts. <br />Individual Reporting of Possible Errors and Program Abuse <br />SAHA Policy <br /> <br />SAHA will encourage staff, program participants, and the public to report possible <br />program abuse. <br />14-I.C. INVESTIGATING ERRORS AND PROGRAM ABUSE <br />When the PHA Will Investigate <br />SAHA Policy <br /> <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 <br />investigation. In order for SAHA to investigate, the allegation must contain at least one <br />independently-verifiable item of information, such as the name of an employer or the <br />name of an unauthorized household member. <br />SAHA will investigate inconsistent information related to the family that is identified <br />through file reviews and the verification process. <br />SAHA may use third party investigators for detailed investigations. <br /> <br />Consent to Release of Information \[24 CFR 982.516\] <br />The PHA may investigate possible instances of error or abuse using all available PHA and public <br />records. If necessary, the PHA will require HCV families to give consent to the release of <br />additional information. <br />Analysis and Findings <br />SAHA Policy <br /> <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 />shows that the fact sought to be proved is more probable than not. Preponderance of evidence <br />may not be determined by the number of witnesses, but by the greater weight of all evidence <br /> <br />Page 14-3 <br />04/01/14 <br /> <br />