FAC Explorer

Audit 305773

FY End
2023-12-31
Total Expended
$3.25M
Findings
2
Programs
1
Organization: Boulevard Gardens Senior Housing 092-Ee025wah (MN)
Year: 2023 Accepted: 2024-05-08
Auditor: Mahoney Ulbrich Christiansen and Russ PA

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
396158 2023-001 Material Weakness - E
972600 2023-001 Material Weakness - E

Programs

ALN Program Spent Major Findings
14.157 Supportive Housing for the Elderly $3.25M Yes 1

Contacts

Name Title Type
UQJBQ895GRN7 Elyse Clifford Auditee
6512889014 Katie McDonnell Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: 1) Expenditures reported on the Schedule are reported on the accrual basis of accounting, except for the capital advance as discussed below. 2) Boulevard Gardens Senior Housing’s federal award is not based on eligible costs incurred. De Minimis Rate Used: N Rate Explanation: Boulevard Gardens Senior Housing has not made an election related to the use of the 10% de minimis indirect cost rate described in the Uniform Guidance. This schedule includes the federal grant activity of Boulevard Gardens Senior Housing under programs of the federal government for the year ended December 31, 2023. The information presented 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 (the Uniform Guidance). Because the schedule presents only a selected portion of the operations of Boulevard Gardens Senior Housing, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Boulevard Gardens Senior Housing.
Title: Capital Advance Accounting Policies: 1) Expenditures reported on the Schedule are reported on the accrual basis of accounting, except for the capital advance as discussed below. 2) Boulevard Gardens Senior Housing’s federal award is not based on eligible costs incurred. De Minimis Rate Used: N Rate Explanation: Boulevard Gardens Senior Housing has not made an election related to the use of the 10% de minimis indirect cost rate described in the Uniform Guidance. Federal expenditures reported as capital advances represent the beginning of the year balance of a capital advance outstanding from the previous years for which the grantor imposes continuing compliance requirements. The balance of the capital advance outstanding as of December 31, 2023 was $3,120,200.

Finding Details

Finding 2023-001
2023-001 – Income Certifications Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 – Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants’ responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants’ rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 46 units, 5 were tested. Three units selected for testing at this property resulted in noncompliance. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand the finding to be prevalent at the Organization throughout the year. Management has reported that as of December 31, 2023, there were seven incomplete or late annual recertifications for Boulevard Gardens Senior Housing. Cause - Inexperienced site employees, changes in procedures for processing tenant files, and a global pandemic restricting personal interactions between site employees and tenants all contributed to multiple breakdowns in procedures, which resulted in numerous failures to timely complete the required annual recertifications. Effect - The Organization was not in compliance with the Compliance Supplement. In addition, rental assistance may be delayed and changes in rental assistance will be effective from the tenants’ annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Identification of repeat finding - No Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding, and has implemented strategies to address these issues throughout 2023, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations.
Finding 2023-001
2023-001 – Income Certifications Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 – Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants’ responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants’ rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 46 units, 5 were tested. Three units selected for testing at this property resulted in noncompliance. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand the finding to be prevalent at the Organization throughout the year. Management has reported that as of December 31, 2023, there were seven incomplete or late annual recertifications for Boulevard Gardens Senior Housing. Cause - Inexperienced site employees, changes in procedures for processing tenant files, and a global pandemic restricting personal interactions between site employees and tenants all contributed to multiple breakdowns in procedures, which resulted in numerous failures to timely complete the required annual recertifications. Effect - The Organization was not in compliance with the Compliance Supplement. In addition, rental assistance may be delayed and changes in rental assistance will be effective from the tenants’ annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Identification of repeat finding - No Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding, and has implemented strategies to address these issues throughout 2023, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations.