Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance
Repeat of prior year findings: 2021-001 and 2022-002
Assistance Listing Number: 14.181 and 14.239
Federal Agency: U.S. Department of Housing and Urban Development
Federal Award Number: Not applicable
Federal Award Year: July 1, 2022 - June 30, 2023
Pass-Through Entity: Not applicable
Criteria: Section 811 of the National Affordable Housing Act provides funding for housingCause: Lack of management oversight due to turnover. As a result, management has not been able to
implement their planned corrective actions in a timely fashion.
Recommendation: The Corporation should have procedures in place to ensure documentation is
maintained accordance with its requirements.
Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for
portfolio property managers to effectively manage tenant files at each building location. Historically, the
management and auditing of tenant files was entirely under the process flows for property management
team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files
throughout year to assure tenant files are accurate and audit ready at any given time.
Inglis Housing Corporation hired new a new property management Executive Director in August 2023.
Under her leadership the team has made extensive progress updating and bringing all PRACs, tenant
recertifications, and tenant files into compliance. There has been in depth training for the property
management team on the usage of a newly implemented property management system. All staff have or
will attend external training classes for tax credit and HUD property management functions. The property
management team is working on reviewing and updating all tenant files with a goal of being in compliance
for the June 30, 2024 audit. for persons with
disabilities. To qualify as disabled, the household must consist of at least one person who is an adult
(18 years or older) with a disability, two or more persons with disabilities living together, or a surviving
household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section 891.505).
Residents must also qualify as very low-income households to be eligible (42 USC 8013). Eligibility is
only determined at move-in or at initial certification except in circumstances whereas family composition
changes after initial occupancy a determination must be made as to whether the remaining member of
the household will be eligible to receive assistance. Eligibility requirements are found in HUD's regulations
at 24 CFR Part 5.
The HOME Investments Partnerships program also has income targeting requirements. Only low income
or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR
section 92.1).
The Corporation is responsible for annually reexamining incomes of households occupying assisted units
and make appropriate adjustments to the tenant payment and the project rental assistance payment
(24 CFR section 891.410). Assistance applicants shall submit signed consent forms upon initial
application and at reexamination (24 CFR section 5.230).
Questioned Cost: Not determinable.
Condition/Context: During our risk assessment procedures and follow-up on the prior year findings, we
noted that the tenant eligibility issues that were identified in the prior years persisted and worsened. The
issues affecting tenant eligibility include missing documentation to support the eligibility requirements and
tenant recertification. As a result, we did not select a sample from the population for testing.
Effect: Insufficient documentation of tenant eligibility. Similar issues over tenant recertification has caused
delays in obtaining renewal of the Corporation's PRAC contract. As a result of not renewing the PRAC
contract timely there were operating cash flow deficiencies resulting in significant growth in related party
balances due to the parent entity and unpaid subsidies at June 30, 2023.
Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance
Repeat of prior year findings: 2021-001 and 2022-002
Assistance Listing Number: 14.181 and 14.239
Federal Agency: U.S. Department of Housing and Urban Development
Federal Award Number: Not applicable
Federal Award Year: July 1, 2022 - June 30, 2023
Pass-Through Entity: Not applicable
Criteria: Section 811 of the National Affordable Housing Act provides funding for housingCause: Lack of management oversight due to turnover. As a result, management has not been able to
implement their planned corrective actions in a timely fashion.
Recommendation: The Corporation should have procedures in place to ensure documentation is
maintained accordance with its requirements.
Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for
portfolio property managers to effectively manage tenant files at each building location. Historically, the
management and auditing of tenant files was entirely under the process flows for property management
team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files
throughout year to assure tenant files are accurate and audit ready at any given time.
Inglis Housing Corporation hired new a new property management Executive Director in August 2023.
Under her leadership the team has made extensive progress updating and bringing all PRACs, tenant
recertifications, and tenant files into compliance. There has been in depth training for the property
management team on the usage of a newly implemented property management system. All staff have or
will attend external training classes for tax credit and HUD property management functions. The property
management team is working on reviewing and updating all tenant files with a goal of being in compliance
for the June 30, 2024 audit. for persons with
disabilities. To qualify as disabled, the household must consist of at least one person who is an adult
(18 years or older) with a disability, two or more persons with disabilities living together, or a surviving
household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section 891.505).
Residents must also qualify as very low-income households to be eligible (42 USC 8013). Eligibility is
only determined at move-in or at initial certification except in circumstances whereas family composition
changes after initial occupancy a determination must be made as to whether the remaining member of
the household will be eligible to receive assistance. Eligibility requirements are found in HUD's regulations
at 24 CFR Part 5.
The HOME Investments Partnerships program also has income targeting requirements. Only low income
or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR
section 92.1).
The Corporation is responsible for annually reexamining incomes of households occupying assisted units
and make appropriate adjustments to the tenant payment and the project rental assistance payment
(24 CFR section 891.410). Assistance applicants shall submit signed consent forms upon initial
application and at reexamination (24 CFR section 5.230).
Questioned Cost: Not determinable.
Condition/Context: During our risk assessment procedures and follow-up on the prior year findings, we
noted that the tenant eligibility issues that were identified in the prior years persisted and worsened. The
issues affecting tenant eligibility include missing documentation to support the eligibility requirements and
tenant recertification. As a result, we did not select a sample from the population for testing.
Effect: Insufficient documentation of tenant eligibility. Similar issues over tenant recertification has caused
delays in obtaining renewal of the Corporation's PRAC contract. As a result of not renewing the PRAC
contract timely there were operating cash flow deficiencies resulting in significant growth in related party
balances due to the parent entity and unpaid subsidies at June 30, 2023.
Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance
Repeat of prior year findings: 2021-001 and 2022-002
Assistance Listing Number: 14.181 and 14.239
Federal Agency: U.S. Department of Housing and Urban Development
Federal Award Number: Not applicable
Federal Award Year: July 1, 2022 - June 30, 2023
Pass-Through Entity: Not applicable
Criteria: Section 811 of the National Affordable Housing Act provides funding for housingCause: Lack of management oversight due to turnover. As a result, management has not been able to
implement their planned corrective actions in a timely fashion.
Recommendation: The Corporation should have procedures in place to ensure documentation is
maintained accordance with its requirements.
Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for
portfolio property managers to effectively manage tenant files at each building location. Historically, the
management and auditing of tenant files was entirely under the process flows for property management
team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files
throughout year to assure tenant files are accurate and audit ready at any given time.
Inglis Housing Corporation hired new a new property management Executive Director in August 2023.
Under her leadership the team has made extensive progress updating and bringing all PRACs, tenant
recertifications, and tenant files into compliance. There has been in depth training for the property
management team on the usage of a newly implemented property management system. All staff have or
will attend external training classes for tax credit and HUD property management functions. The property
management team is working on reviewing and updating all tenant files with a goal of being in compliance
for the June 30, 2024 audit. for persons with
disabilities. To qualify as disabled, the household must consist of at least one person who is an adult
(18 years or older) with a disability, two or more persons with disabilities living together, or a surviving
household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section 891.505).
Residents must also qualify as very low-income households to be eligible (42 USC 8013). Eligibility is
only determined at move-in or at initial certification except in circumstances whereas family composition
changes after initial occupancy a determination must be made as to whether the remaining member of
the household will be eligible to receive assistance. Eligibility requirements are found in HUD's regulations
at 24 CFR Part 5.
The HOME Investments Partnerships program also has income targeting requirements. Only low income
or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR
section 92.1).
The Corporation is responsible for annually reexamining incomes of households occupying assisted units
and make appropriate adjustments to the tenant payment and the project rental assistance payment
(24 CFR section 891.410). Assistance applicants shall submit signed consent forms upon initial
application and at reexamination (24 CFR section 5.230).
Questioned Cost: Not determinable.
Condition/Context: During our risk assessment procedures and follow-up on the prior year findings, we
noted that the tenant eligibility issues that were identified in the prior years persisted and worsened. The
issues affecting tenant eligibility include missing documentation to support the eligibility requirements and
tenant recertification. As a result, we did not select a sample from the population for testing.
Effect: Insufficient documentation of tenant eligibility. Similar issues over tenant recertification has caused
delays in obtaining renewal of the Corporation's PRAC contract. As a result of not renewing the PRAC
contract timely there were operating cash flow deficiencies resulting in significant growth in related party
balances due to the parent entity and unpaid subsidies at June 30, 2023.
Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance
Repeat of prior year findings: 2021-001 and 2022-002
Assistance Listing Number: 14.181 and 14.239
Federal Agency: U.S. Department of Housing and Urban Development
Federal Award Number: Not applicable
Federal Award Year: July 1, 2022 - June 30, 2023
Pass-Through Entity: Not applicable
Criteria: Section 811 of the National Affordable Housing Act provides funding for housingCause: Lack of management oversight due to turnover. As a result, management has not been able to
implement their planned corrective actions in a timely fashion.
Recommendation: The Corporation should have procedures in place to ensure documentation is
maintained accordance with its requirements.
Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for
portfolio property managers to effectively manage tenant files at each building location. Historically, the
management and auditing of tenant files was entirely under the process flows for property management
team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files
throughout year to assure tenant files are accurate and audit ready at any given time.
Inglis Housing Corporation hired new a new property management Executive Director in August 2023.
Under her leadership the team has made extensive progress updating and bringing all PRACs, tenant
recertifications, and tenant files into compliance. There has been in depth training for the property
management team on the usage of a newly implemented property management system. All staff have or
will attend external training classes for tax credit and HUD property management functions. The property
management team is working on reviewing and updating all tenant files with a goal of being in compliance
for the June 30, 2024 audit. for persons with
disabilities. To qualify as disabled, the household must consist of at least one person who is an adult
(18 years or older) with a disability, two or more persons with disabilities living together, or a surviving
household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section 891.505).
Residents must also qualify as very low-income households to be eligible (42 USC 8013). Eligibility is
only determined at move-in or at initial certification except in circumstances whereas family composition
changes after initial occupancy a determination must be made as to whether the remaining member of
the household will be eligible to receive assistance. Eligibility requirements are found in HUD's regulations
at 24 CFR Part 5.
The HOME Investments Partnerships program also has income targeting requirements. Only low income
or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR
section 92.1).
The Corporation is responsible for annually reexamining incomes of households occupying assisted units
and make appropriate adjustments to the tenant payment and the project rental assistance payment
(24 CFR section 891.410). Assistance applicants shall submit signed consent forms upon initial
application and at reexamination (24 CFR section 5.230).
Questioned Cost: Not determinable.
Condition/Context: During our risk assessment procedures and follow-up on the prior year findings, we
noted that the tenant eligibility issues that were identified in the prior years persisted and worsened. The
issues affecting tenant eligibility include missing documentation to support the eligibility requirements and
tenant recertification. As a result, we did not select a sample from the population for testing.
Effect: Insufficient documentation of tenant eligibility. Similar issues over tenant recertification has caused
delays in obtaining renewal of the Corporation's PRAC contract. As a result of not renewing the PRAC
contract timely there were operating cash flow deficiencies resulting in significant growth in related party
balances due to the parent entity and unpaid subsidies at June 30, 2023.
Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance
Repeat of prior year findings: 2021-001 and 2022-002
Assistance Listing Number: 14.181 and 14.239
Federal Agency: U.S. Department of Housing and Urban Development
Federal Award Number: Not applicable
Federal Award Year: July 1, 2022 - June 30, 2023
Pass-Through Entity: Not applicable
Criteria: Section 811 of the National Affordable Housing Act provides funding for housingCause: Lack of management oversight due to turnover. As a result, management has not been able to
implement their planned corrective actions in a timely fashion.
Recommendation: The Corporation should have procedures in place to ensure documentation is
maintained accordance with its requirements.
Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for
portfolio property managers to effectively manage tenant files at each building location. Historically, the
management and auditing of tenant files was entirely under the process flows for property management
team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files
throughout year to assure tenant files are accurate and audit ready at any given time.
Inglis Housing Corporation hired new a new property management Executive Director in August 2023.
Under her leadership the team has made extensive progress updating and bringing all PRACs, tenant
recertifications, and tenant files into compliance. There has been in depth training for the property
management team on the usage of a newly implemented property management system. All staff have or
will attend external training classes for tax credit and HUD property management functions. The property
management team is working on reviewing and updating all tenant files with a goal of being in compliance
for the June 30, 2024 audit. for persons with
disabilities. To qualify as disabled, the household must consist of at least one person who is an adult
(18 years or older) with a disability, two or more persons with disabilities living together, or a surviving
household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section 891.505).
Residents must also qualify as very low-income households to be eligible (42 USC 8013). Eligibility is
only determined at move-in or at initial certification except in circumstances whereas family composition
changes after initial occupancy a determination must be made as to whether the remaining member of
the household will be eligible to receive assistance. Eligibility requirements are found in HUD's regulations
at 24 CFR Part 5.
The HOME Investments Partnerships program also has income targeting requirements. Only low income
or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR
section 92.1).
The Corporation is responsible for annually reexamining incomes of households occupying assisted units
and make appropriate adjustments to the tenant payment and the project rental assistance payment
(24 CFR section 891.410). Assistance applicants shall submit signed consent forms upon initial
application and at reexamination (24 CFR section 5.230).
Questioned Cost: Not determinable.
Condition/Context: During our risk assessment procedures and follow-up on the prior year findings, we
noted that the tenant eligibility issues that were identified in the prior years persisted and worsened. The
issues affecting tenant eligibility include missing documentation to support the eligibility requirements and
tenant recertification. As a result, we did not select a sample from the population for testing.
Effect: Insufficient documentation of tenant eligibility. Similar issues over tenant recertification has caused
delays in obtaining renewal of the Corporation's PRAC contract. As a result of not renewing the PRAC
contract timely there were operating cash flow deficiencies resulting in significant growth in related party
balances due to the parent entity and unpaid subsidies at June 30, 2023.
Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance
Repeat of prior year findings: 2021-001 and 2022-002
Assistance Listing Number: 14.181 and 14.239
Federal Agency: U.S. Department of Housing and Urban Development
Federal Award Number: Not applicable
Federal Award Year: July 1, 2022 - June 30, 2023
Pass-Through Entity: Not applicable
Criteria: Section 811 of the National Affordable Housing Act provides funding for housingCause: Lack of management oversight due to turnover. As a result, management has not been able to
implement their planned corrective actions in a timely fashion.
Recommendation: The Corporation should have procedures in place to ensure documentation is
maintained accordance with its requirements.
Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for
portfolio property managers to effectively manage tenant files at each building location. Historically, the
management and auditing of tenant files was entirely under the process flows for property management
team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files
throughout year to assure tenant files are accurate and audit ready at any given time.
Inglis Housing Corporation hired new a new property management Executive Director in August 2023.
Under her leadership the team has made extensive progress updating and bringing all PRACs, tenant
recertifications, and tenant files into compliance. There has been in depth training for the property
management team on the usage of a newly implemented property management system. All staff have or
will attend external training classes for tax credit and HUD property management functions. The property
management team is working on reviewing and updating all tenant files with a goal of being in compliance
for the June 30, 2024 audit. for persons with
disabilities. To qualify as disabled, the household must consist of at least one person who is an adult
(18 years or older) with a disability, two or more persons with disabilities living together, or a surviving
household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section 891.505).
Residents must also qualify as very low-income households to be eligible (42 USC 8013). Eligibility is
only determined at move-in or at initial certification except in circumstances whereas family composition
changes after initial occupancy a determination must be made as to whether the remaining member of
the household will be eligible to receive assistance. Eligibility requirements are found in HUD's regulations
at 24 CFR Part 5.
The HOME Investments Partnerships program also has income targeting requirements. Only low income
or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR
section 92.1).
The Corporation is responsible for annually reexamining incomes of households occupying assisted units
and make appropriate adjustments to the tenant payment and the project rental assistance payment
(24 CFR section 891.410). Assistance applicants shall submit signed consent forms upon initial
application and at reexamination (24 CFR section 5.230).
Questioned Cost: Not determinable.
Condition/Context: During our risk assessment procedures and follow-up on the prior year findings, we
noted that the tenant eligibility issues that were identified in the prior years persisted and worsened. The
issues affecting tenant eligibility include missing documentation to support the eligibility requirements and
tenant recertification. As a result, we did not select a sample from the population for testing.
Effect: Insufficient documentation of tenant eligibility. Similar issues over tenant recertification has caused
delays in obtaining renewal of the Corporation's PRAC contract. As a result of not renewing the PRAC
contract timely there were operating cash flow deficiencies resulting in significant growth in related party
balances due to the parent entity and unpaid subsidies at June 30, 2023.