FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT
Department of Housing and Urban Development Finding, 2023-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157
STATEMENT OF CONDITION
One tenant file, out of six files reviewed, incorrectly accounted for tenant’s income, which resulted in undercharging the tenant $22 a month in rent. CRITERIA
HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to properly calculate tenants rent derived from the appropriate documents on file for tenants.
EFFECT OF CONDITION
The tenant was improperly undercharged $264 of rent for the year ended December 31, 2023. HUD was overcharged $264 of additional rental assistance payments for the year ended December 31, 2023.
CONTEXT
During audit fieldwork, six tenant files from a statistically valid sample were examined for compliance with tenant eligibility criteria and HUD lease requirements. Of the six tenant files examined, income for one tenant was incorrectly accounted for, resulting in the wrong calculation of tenant rent and HUD tenant assistance payments.
CAUSE OF CONDITION
Management mistakenly did not ensure the proper income was used to calculate the tenant’s rent.
RECOMMENDATION
The auditor recommends ensuring all tenants’ paperwork is thoroughly reviewed and accurately used in the calculation of the tenant’s required monthly rent and HUD’s tenant assistance payments.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS
The Project will be billing the tenant for the $264 and reimbursing HUD for additional tenant assistance payments of $264 due to the Project.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT (CONTINUED)
Department of Housing and Urban Development Finding, 2023-002: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157
STATEMENT OF CONDITION
One tenant file, out of six files reviewed, was for a tenant who moved in during the year and management did not properly generate the Enterprise Income Verification (EIV) report timely.
CRITERIA
HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to review the EIV report within 90 days after transmission of the move in certification to the Tenant Rental Assistance Certification System (TRACS).
EFFECT OF CONDITION
The EIV report for the tenant moved in was not generated until after the 90-day period specified by HUD.
CONTEXT
During audit fieldwork, six files from a statistically valid sample were examined for compliance with tenant eligibility criteria. Of the six tenant files examined, one tenant was a new move in. The tenant’s file did not contain the EIV verified in the required 90-day timeframe.
CAUSE OF CONDITION
The procedures to ensure compliance over HUD tenant compliance, including EIV verification, were not followed timely.
RECOMMENDATION
The auditor recommends ensuring all current and new staff are trained on tenants’ 90-day EIV reports and ensuring they are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS
The Project will be monitoring use of the EIV system for move ins and recertifications.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT (CONTINUED)
Department of Housing and Urban Development Finding, 2023-003: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157
STATEMENT OF CONDITION
All required deposits were not made to the Reserve for Replacement account for the years ended December 31, 2023 and 2022, totaling $5,727 and $24,287 outstanding as of December 31, 2023.
CRITERIA
HUD Handbook 4350.1 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to make monthly deposits to the Reserve for Replacement account based on the Project’s monthly deposit authorized by HUD.
EFFECT OF CONDITION
Management did not make all required deposits to the Reserve for Replacement account in 2023.
CONTEXT
During audit fieldwork, the Reserve for Replacement accounts were tested for compliance with required monthly deposits. Insufficient monthly deposits were noted on the bank statements.
CAUSE OF CONDITION
Management did not make all monthly deposits to the Reserve for Replacement account due to cash flow issues during 2023.
RECOMMENDATION
The auditor recommends the Reserve for Replacement be properly funded on a monthly basis.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS
The Project has suffered dramatically from the results of COVID-19. During all years prior to 2022, the Reserve for Replacement has been in compliance. Although HUD did help with small COVID-19 grants, it was not sufficient to overcome the costs.
Properties of 50-units and less suffered far more during COVID-19 than the larger developments due to the economies of scale. It should be noted that in addition to the Reserve for Replacement that was not funded in 2023, the property management firm was also not paid $24,523.
Management received a substantial rent increase in June 2023 and plans to make all required deposits in 2024 when they will begin to see the effects of this increase.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT
Department of Housing and Urban Development Finding, 2023-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157
STATEMENT OF CONDITION
One tenant file, out of six files reviewed, incorrectly accounted for tenant’s income, which resulted in undercharging the tenant $22 a month in rent. CRITERIA
HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to properly calculate tenants rent derived from the appropriate documents on file for tenants.
EFFECT OF CONDITION
The tenant was improperly undercharged $264 of rent for the year ended December 31, 2023. HUD was overcharged $264 of additional rental assistance payments for the year ended December 31, 2023.
CONTEXT
During audit fieldwork, six tenant files from a statistically valid sample were examined for compliance with tenant eligibility criteria and HUD lease requirements. Of the six tenant files examined, income for one tenant was incorrectly accounted for, resulting in the wrong calculation of tenant rent and HUD tenant assistance payments.
CAUSE OF CONDITION
Management mistakenly did not ensure the proper income was used to calculate the tenant’s rent.
RECOMMENDATION
The auditor recommends ensuring all tenants’ paperwork is thoroughly reviewed and accurately used in the calculation of the tenant’s required monthly rent and HUD’s tenant assistance payments.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS
The Project will be billing the tenant for the $264 and reimbursing HUD for additional tenant assistance payments of $264 due to the Project.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT (CONTINUED)
Department of Housing and Urban Development Finding, 2023-002: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157
STATEMENT OF CONDITION
One tenant file, out of six files reviewed, was for a tenant who moved in during the year and management did not properly generate the Enterprise Income Verification (EIV) report timely.
CRITERIA
HUD Handbook 4350.3 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to review the EIV report within 90 days after transmission of the move in certification to the Tenant Rental Assistance Certification System (TRACS).
EFFECT OF CONDITION
The EIV report for the tenant moved in was not generated until after the 90-day period specified by HUD.
CONTEXT
During audit fieldwork, six files from a statistically valid sample were examined for compliance with tenant eligibility criteria. Of the six tenant files examined, one tenant was a new move in. The tenant’s file did not contain the EIV verified in the required 90-day timeframe.
CAUSE OF CONDITION
The procedures to ensure compliance over HUD tenant compliance, including EIV verification, were not followed timely.
RECOMMENDATION
The auditor recommends ensuring all current and new staff are trained on tenants’ 90-day EIV reports and ensuring they are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS
The Project will be monitoring use of the EIV system for move ins and recertifications.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT (CONTINUED)
Department of Housing and Urban Development Finding, 2023-003: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157
STATEMENT OF CONDITION
All required deposits were not made to the Reserve for Replacement account for the years ended December 31, 2023 and 2022, totaling $5,727 and $24,287 outstanding as of December 31, 2023.
CRITERIA
HUD Handbook 4350.1 Revision 1 for HUD Subsidized Multifamily Housing Programs requires owners to make monthly deposits to the Reserve for Replacement account based on the Project’s monthly deposit authorized by HUD.
EFFECT OF CONDITION
Management did not make all required deposits to the Reserve for Replacement account in 2023.
CONTEXT
During audit fieldwork, the Reserve for Replacement accounts were tested for compliance with required monthly deposits. Insufficient monthly deposits were noted on the bank statements.
CAUSE OF CONDITION
Management did not make all monthly deposits to the Reserve for Replacement account due to cash flow issues during 2023.
RECOMMENDATION
The auditor recommends the Reserve for Replacement be properly funded on a monthly basis.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS
The Project has suffered dramatically from the results of COVID-19. During all years prior to 2022, the Reserve for Replacement has been in compliance. Although HUD did help with small COVID-19 grants, it was not sufficient to overcome the costs.
Properties of 50-units and less suffered far more during COVID-19 than the larger developments due to the economies of scale. It should be noted that in addition to the Reserve for Replacement that was not funded in 2023, the property management firm was also not paid $24,523.
Management received a substantial rent increase in June 2023 and plans to make all required deposits in 2024 when they will begin to see the effects of this increase.