Audit 293201

FY End
2023-06-30
Total Expended
$3.40M
Findings
4
Programs
2
Organization: Saint Joseph's Tower, INC (IN)
Year: 2023 Accepted: 2024-03-01

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
371933 2023-001 Significant Deficiency - E
371934 2023-001 Significant Deficiency - E
948375 2023-001 Significant Deficiency - E
948376 2023-001 Significant Deficiency - E

Programs

ALN Program Spent Major Findings
14.157 Supportive Housing for the Elderly $2.79M Yes 1
14.195 Section 8 Housing Assistance Payments Program $615,970 Yes 1

Contacts

Name Title Type
MMDLEFKUNHD3 David Defrain Auditee
7343431312 Justin Masters Auditor
No contacts on file

Notes to SEFA

Title: Note 3. Pass-Through Agency Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Saint Joseph's Tower, Inc. (the "Project") under programs of the federal government for the year ended June 30, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"). Because the Schedule presents only a selected portion of the operations of the Project, it is not intended to and does not present the net assets, changes in net assets or cash flows of the Project. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance or other applicable guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: For purposes of charging indirect costs to federal awards, the Project has not elected to use the 10 percent de minimis cost rate as permitted by §200.414 of the Uniform Guidance. The Project receives Section 8 Housing Assistance Payments as a subaward from Indiana Quadel ("Quadel").
Title: Note 4. Loan Program - Supportive Housing for the Elderly (ALN 14.157) Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Saint Joseph's Tower, Inc. (the "Project") under programs of the federal government for the year ended June 30, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"). Because the Schedule presents only a selected portion of the operations of the Project, it is not intended to and does not present the net assets, changes in net assets or cash flows of the Project. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance or other applicable guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: For purposes of charging indirect costs to federal awards, the Project has not elected to use the 10 percent de minimis cost rate as permitted by §200.414 of the Uniform Guidance. The Project has an outstanding loan that is guaranteed by the U.S. Department of Housing and Urban Development. As of June 30, 2023, the outstanding balance on the loan was $2,680,737, and is presented on the statement of financial position net of the related deferred financing costs.

Finding Details

2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Eligibility) Federal program U.S. Department of Housing and Urban Development ●   Supportive Housing for the Elderly (ALN# 14.157) ●   Section 8 Housing Assistance Payments Program (ALN# 14.195) Criteria. Under Section 8 of the Housing Act of 1937 and Section 202 of the National Housing Act of 1959, Project management is responsible for performing an examination of and obtaining support for items of income, assets, and expenses, for proper calculation of tenant assistance payments of applying residents, and annual recertification and calculation of such information thereafter, and for obtaining signed and properly completed forms. Project management is also responsible for disbursing refunds to former tenants within 60 days of move out. Condition. Out of a sample of 8 tenant files, we noted three instances where an EIV was not run for a tenant within 90 days of move in. Additionally, out of a sample of 8 tenant files, we noted one instance where a refund check was not disbursed to the tenant within 60 days of move out. Cause. Management does not appear to have sufficient internal control procedures in place to properly implement all of HUD's program requirements. Effect. As a result of this condition, employees did not follow HUD guideline procedures. While there were no differences in the amount of subsidies allowed upon review of the subsequent EIV compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Additionally, a former tenant was not disbursed a refund in a timely manner under the HUD guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that management should strengthen their current policies and follow a documented review process for all new, existing, and former resident files and ensure that this review occurs on a timely basis. Further, we recommend that management ensure HUD guideline procedures be followed. View of Responsible Officials. Management agrees with this comment and has prepared a corrective action plan.
2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Eligibility) Federal program U.S. Department of Housing and Urban Development ●   Supportive Housing for the Elderly (ALN# 14.157) ●   Section 8 Housing Assistance Payments Program (ALN# 14.195) Criteria. Under Section 8 of the Housing Act of 1937 and Section 202 of the National Housing Act of 1959, Project management is responsible for performing an examination of and obtaining support for items of income, assets, and expenses, for proper calculation of tenant assistance payments of applying residents, and annual recertification and calculation of such information thereafter, and for obtaining signed and properly completed forms. Project management is also responsible for disbursing refunds to former tenants within 60 days of move out. Condition. Out of a sample of 8 tenant files, we noted three instances where an EIV was not run for a tenant within 90 days of move in. Additionally, out of a sample of 8 tenant files, we noted one instance where a refund check was not disbursed to the tenant within 60 days of move out. Cause. Management does not appear to have sufficient internal control procedures in place to properly implement all of HUD's program requirements. Effect. As a result of this condition, employees did not follow HUD guideline procedures. While there were no differences in the amount of subsidies allowed upon review of the subsequent EIV compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Additionally, a former tenant was not disbursed a refund in a timely manner under the HUD guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that management should strengthen their current policies and follow a documented review process for all new, existing, and former resident files and ensure that this review occurs on a timely basis. Further, we recommend that management ensure HUD guideline procedures be followed. View of Responsible Officials. Management agrees with this comment and has prepared a corrective action plan.
2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Eligibility) Federal program U.S. Department of Housing and Urban Development ●   Supportive Housing for the Elderly (ALN# 14.157) ●   Section 8 Housing Assistance Payments Program (ALN# 14.195) Criteria. Under Section 8 of the Housing Act of 1937 and Section 202 of the National Housing Act of 1959, Project management is responsible for performing an examination of and obtaining support for items of income, assets, and expenses, for proper calculation of tenant assistance payments of applying residents, and annual recertification and calculation of such information thereafter, and for obtaining signed and properly completed forms. Project management is also responsible for disbursing refunds to former tenants within 60 days of move out. Condition. Out of a sample of 8 tenant files, we noted three instances where an EIV was not run for a tenant within 90 days of move in. Additionally, out of a sample of 8 tenant files, we noted one instance where a refund check was not disbursed to the tenant within 60 days of move out. Cause. Management does not appear to have sufficient internal control procedures in place to properly implement all of HUD's program requirements. Effect. As a result of this condition, employees did not follow HUD guideline procedures. While there were no differences in the amount of subsidies allowed upon review of the subsequent EIV compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Additionally, a former tenant was not disbursed a refund in a timely manner under the HUD guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that management should strengthen their current policies and follow a documented review process for all new, existing, and former resident files and ensure that this review occurs on a timely basis. Further, we recommend that management ensure HUD guideline procedures be followed. View of Responsible Officials. Management agrees with this comment and has prepared a corrective action plan.
2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Eligibility) Federal program U.S. Department of Housing and Urban Development ●   Supportive Housing for the Elderly (ALN# 14.157) ●   Section 8 Housing Assistance Payments Program (ALN# 14.195) Criteria. Under Section 8 of the Housing Act of 1937 and Section 202 of the National Housing Act of 1959, Project management is responsible for performing an examination of and obtaining support for items of income, assets, and expenses, for proper calculation of tenant assistance payments of applying residents, and annual recertification and calculation of such information thereafter, and for obtaining signed and properly completed forms. Project management is also responsible for disbursing refunds to former tenants within 60 days of move out. Condition. Out of a sample of 8 tenant files, we noted three instances where an EIV was not run for a tenant within 90 days of move in. Additionally, out of a sample of 8 tenant files, we noted one instance where a refund check was not disbursed to the tenant within 60 days of move out. Cause. Management does not appear to have sufficient internal control procedures in place to properly implement all of HUD's program requirements. Effect. As a result of this condition, employees did not follow HUD guideline procedures. While there were no differences in the amount of subsidies allowed upon review of the subsequent EIV compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Additionally, a former tenant was not disbursed a refund in a timely manner under the HUD guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that management should strengthen their current policies and follow a documented review process for all new, existing, and former resident files and ensure that this review occurs on a timely basis. Further, we recommend that management ensure HUD guideline procedures be followed. View of Responsible Officials. Management agrees with this comment and has prepared a corrective action plan.