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HUD & Federal Program PBC Request List

A program-by-program guide to the documents your auditor will request for HUD and federal programs.

By Jonathan Kearney, CPA, Founder, Kearney & Partners · Reference guide

  • Covers HCV, Public Housing, HOME, CDBG, Capital Fund, and HUD Multifamily
  • Organized by compliance area with H3 subsections
  • Companion to the Single Audit PBC checklist

Reference

Program-by-program

HCV, Public Housing, HOME, CDBG, Capital Fund, HUD Multifamily, and more.

  • 12 sections

    Organizational through monitoring

  • Major programs

    Items for tested programs only

  • Year-round

    Maintain records before fieldwork

How to use this list: Not every item applies to every organization. Use the sections relevant to your programs. Provide only the items for federal programs determined to be major and tested for compliance. Maintaining these records year-round, rather than assembling them at fieldwork, is the single biggest driver of a smooth, on-time audit.

Organizational & Governance

Applies to: All entities

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Organizational Documents

  • Organizational chart
  • Current policies and procedures manuals
  • Internal control narratives
  • Updated policies adopted during the year
  • Compliance monitoring procedures
  • Delegation of authority matrix

Governance

  • Board and committee meeting minutes
  • Compliance committee meeting minutes
  • Significant legal correspondence
  • Regulatory correspondence

Federal Award / Single Audit

Applies to: All federal award recipients

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Award Administration

  • Federal award inventory
  • Grant agreements
  • Grant amendments
  • Award notifications
  • Program budgets
  • Approved budget revisions
  • Federal agency correspondence

Financial Reporting

  • Schedule of Expenditures of Federal Awards (SEFA)
  • SEFA preparation support
  • Evidence of management review of the SEFA
  • Financial reports submitted to grantors
  • Performance reports submitted to grantors
  • Quarterly, annual, and final reports
  • Grant closeout reports

Draws and Reimbursements

  • Draw request listings
  • Draw support
  • Reimbursement requests and supporting expenditures
  • Cash receipts supporting grant revenues
  • Grant reconciliations

Compliance Monitoring

  • Internal compliance reviews
  • Monitoring reviews performed by agencies
  • Corrective action plans
  • Follow-up on prior findings
  • Documentation of management oversight

Uniform Guidance

  • Documentation of Uniform Guidance implementation
  • Internal control documentation
  • Allowable cost procedures
  • Procurement procedures
  • Equipment management procedures
  • Subrecipient monitoring procedures
  • Procedures for safeguarding protected and personally identifiable information

Procurement Compliance

Applies to: All entities with federal procurement

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Procurement Population

  • Listing of procurements during the audit period
  • Listing of contracts awarded during the period
  • Listing of active contracts

Procurement Files (for selections)

  • Solicitation documents
  • Bid packages
  • Proposals received
  • Bid tabulations
  • Evaluation worksheets
  • Award documentation
  • Contract approvals
  • Conflict-of-interest documentation
  • Sole-source justifications
  • Contract amendments

Disbursement Support (for selections)

  • Purchase orders
  • Invoices
  • Receiving reports
  • Vendor contracts
  • Approval documentation
  • Cancelled checks and wire support

Cash Testing

Applies to: All entities

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Cash Receipts Testing

  • Deposit listings
  • Bank statements
  • Deposit slips
  • Revenue support
  • Grant draw support
  • Interest income support
  • Journal entry support
  • Cash receipt reconciliations

Cash Disbursements Testing

  • Disbursement listings
  • Invoice packages
  • Contracts and purchase orders
  • Approval support
  • Cancelled checks and wire confirmations
  • General ledger coding support

Housing Choice Voucher (HCV / MSV / EHV)

Applies to: PHAs administering vouchers

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Program Administration

  • Payment standards
  • Utility allowance schedules
  • Waiting list reports
  • Move-in and move-out reports
  • New admissions reports
  • Voucher management reports (VMS)
  • Program performance reports
  • Administrative plans

Tenant File Testing (for selections)

  • HUD Form 50058
  • Lease agreement
  • Housing Assistance Payment (HAP) contract
  • Tenancy addendum
  • Utility allowance documentation
  • Rent calculation worksheet
  • Income certifications
  • Background screening documentation
  • Social Security verification
  • Move-in and move-out certifications
  • Interim and annual recertifications
  • Transfer documentation

Income Verification (EIV)

  • Existing Tenant Search results
  • Post move-in EIV review information
  • Annual recertification EIV information
  • Income and employment verification
  • Benefit verification and Social Security award letters
  • Contribution letters
  • Zero-income certifications
  • Pay stubs
  • Workers' compensation support
  • Income discrepancy explanations

HQS / Inspection Compliance

  • Initial, annual, and failed inspection reports
  • Reinspection reports
  • Emergency deficiency documentation
  • 24-hour correction support
  • Passing inspection reports
  • HAP abatement support
  • Owner notification support

Public Housing

Applies to: Public Housing Authorities

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Admissions and Occupancy

  • Rent rolls
  • Lease documents
  • Rent adjustment forms
  • Choice of rent forms
  • Initial eligibility support
  • Annual recertification support
  • Tenant income calculations
  • HUD Form 50058

Waiting List Testing

  • Waiting lists
  • Lottery documentation
  • Tenant ranking documentation
  • Waitlist removal support
  • Eligibility determination support

HOME Program

Applies to: HOME participating jurisdictions & subrecipients

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Program Administration

  • HOME agreements
  • HOME funding schedules
  • Project budgets
  • Draw requests
  • Environmental reviews
  • Project completion reports

Eligibility Testing

  • Income qualification documentation
  • Household eligibility files
  • Income calculation worksheets
  • Verification support

Project Testing

  • Development agreements
  • Construction contracts
  • Cost certifications
  • Completion certifications

CDBG Program

Applies to: CDBG grantees & subrecipients

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Grant Administration

  • Grant agreements
  • Budget approvals
  • Draw requests
  • Performance reports
  • Environmental reviews
  • Closeout documentation

Project Testing

  • Project expenditure support
  • Beneficiary eligibility documentation
  • Construction contracts
  • Contractor payment support
  • Section 3 reporting

Capital Fund Program (CFP)

Applies to: Public Housing Authorities

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Program Compliance

  • Grant agreements
  • Draw requests
  • Capital project listings
  • Environmental review support
  • Construction contract files
  • Contractor payment support
  • Project completion certifications
  • Final financial reports

HUD Multifamily

Applies to: Project-based / multifamily owners & agents

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Property Compliance

  • Management review reports
  • REAC inspections and physical inspection reports
  • Rent schedules
  • Regulatory agreements
  • Tenant Selection Plans
  • Affirmative Fair Housing Marketing Plans
  • HUD correspondence and monthly HUD submissions
  • Budget submissions
  • HUD Form 50059

Financial Compliance

  • Surplus cash calculations
  • Distributions
  • Related-party transactions
  • Management fee support
  • Developer fee support
  • Reserve activity
  • Reserve withdrawal approvals

Loan & Notes Receivable Testing

Applies to: Lending entities & HFAs

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Loan File Testing (for selections)

  • Loan files
  • Borrower applications
  • Income qualification support
  • Loan agreements
  • Promissory notes
  • Mortgage documents
  • Loan modifications
  • Payment histories
  • Interest calculations
  • Delinquency records
  • Collection activity documentation
  • Loan servicing reports

Monitoring & Corrective Actions

Applies to: All entities with prior findings

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Findings and Follow-Up

  • Regulatory findings
  • Internal findings
  • Monitoring reports
  • Corrective action plans
  • Status of corrective actions
  • Agency follow-up correspondence
  • Management response documentation

Want these ready before fieldwork?

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