We audited the U.S. Department of Housing and Urban Development (HUD), Office of Public and Indian Housing’s (PIH) Housing Choice Voucher Program to assess public housing agencies’ (PHA) controls to prevent and combat source of income discrimination. In limited circumstances, Federal law and regulations prohibit source of income discrimination in certain HUD-assisted housing. As of January 2025, 23 states and the District of Columbia had passed statewide laws prohibiting source of income discrimination by officially designating source of income as a protected class, with 16 of them explicitly prohibiting discrimination against housing choice voucher holders. Meanwhile, 152 cities/counties in 27 states have passed local ordinances which prohibit source of income discrimination, including cities and counties in 19 states without a statewide law. Our audit objective was to assess the extent to which PHAs with Housing Choice Voucher Programs in states with a statewide source of income discrimination law implemented controls to prevent and combat source of income discrimination.
PIH has no requirement for PHAs to document source of income discrimination complaints. While PIH uses lease-up rates in overseeing PHAs, PIH does not task PHAs with investigating complaints of source of income discrimination. In the 16 states with a statewide source of income discrimination law that explicitly includes housing choice voucher holders, PHAs reported receiving few source of income discrimination complaints, and most PHAs had guidance for staff and other processes to act on such complaints. Most PHAs’ policies and procedures contained detailed actions for responding to a complaint, while some PHAs only had general statements that the PHA would assist participants. Varying degrees of training and education efforts for staff, program participants, and landlords were observed at the selected PHAs, which some PHA officials believed was an effective means of preventing and combating source of income discrimination. Most PHAs did not have a method for documenting or recording the complaints they received, which PIH encourages as a way PHAs can track complaints and monitor for patterns of discrimination. PIH also encourages PHAs to (1) work with landlords to resolve complaints and (2) inform voucher holders of their right to file a complaint with the appropriate local fair housing organization if complaints are not resolved.
The report contains no recommendations.
