Date Published: March 2019
The percentage of self-certifications for which a grantee has back-up verifiable income documentation, though recommended to be 20%, is ultimately a function of several factors, as noted above. A discovery of no verifiable income documentation available on any sample taken, however, may be a concern or a finding and warrant further investigation, depending on the nature of the activity and the factors discussed above. Missing or incomplete documentation from one beneficiary may be a concern, but a pattern of missing data or income-ineligible beneficiaries could result in a finding of noncompliance. Records must demonstrate that at least 51% of the beneficiaries are income eligible. Any CDBG grantee that relies solely or predominantly on a self-certification approach to income documentation can put an activity at risk if the beneficiaries are later audited and determined to be over the applicable income limit.