Audit 307939

Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance Repeat of prior year findings: 2021-002 and 2022-002 Assistance Listing Number: 14.181 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 housing 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 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 and late recertifications. Similar issues over tenant recertification have 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. Cause: 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.

Finding 2023-002: Required Monthly Deposits to the Replacement Reserve - Significant Deficiency Repeat of prior year finding: 2022-003 Assistance Listing Number: 14.181 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: The Corporation shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 (a)). All disbursements from the reserve must be approved by HUD (24 CFR section 891.405). Questioned Cost: $7,305 in missing deposits. Condition/Context: There were five months where the required deposits were missed. Our sample included all twelve months of required deposits and therefore, the entire population was subject to testing. Effect: Five months of deposits were missed to the reserve for replacement account. Cause: Lack of management oversight due to turnover and delay in rental revenue. Recommendation: The Corporation should have procedures in place to ensure all required monthly deposits are made.

Finding 2023-001: Tenant Eligibility - Material Weakness - Material Noncompliance Repeat of prior year findings: 2021-002 and 2022-002 Assistance Listing Number: 14.181 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 housing 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 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 and late recertifications. Similar issues over tenant recertification have 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. Cause: 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.

Finding 2023-002: Required Monthly Deposits to the Replacement Reserve - Significant Deficiency Repeat of prior year finding: 2022-003 Assistance Listing Number: 14.181 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: The Corporation shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 (a)). All disbursements from the reserve must be approved by HUD (24 CFR section 891.405). Questioned Cost: $7,305 in missing deposits. Condition/Context: There were five months where the required deposits were missed. Our sample included all twelve months of required deposits and therefore, the entire population was subject to testing. Effect: Five months of deposits were missed to the reserve for replacement account. Cause: Lack of management oversight due to turnover and delay in rental revenue. Recommendation: The Corporation should have procedures in place to ensure all required monthly deposits are made.