Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.
Significant Deficiency: Reasonable Rental Rate Comparisons, Significant Deficiency in Internal Control over Compliance; Compliance finding
Assistance Listing #14.267, Department of Housing and Urban Development Continuum of Care program
Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units (24 CFR sections 578.49(b)(2)). The Organization's Rapid Rehousing Program Manual says to "complete rent reasonableness form using 3 comparable apartments," and was revised December 1, 2023 to also include, "One of the units must be for the same owner to ensure reasonable rent will not exceed rents currently being charged by the same owner for comparable unassisted units."
Condition: Of 17 client files selected for testing, 3 rent reasonableness forms did not contain a signature indicating review of the reasonableness of the rental rate. Twelve of the seventeen rent reasonableness forms only included two comparable units and did not have a unit from the same owner.
Cause: The Organization was utilizing a form that did not require a signature and did not require 3 comparable units or a unit from the same owner.
Effect or Potential Effect: Rent paid may be unreasonable compared to units owned by the same landlord.
Recommendation: Consistently ensure reasonableness checks include three units, one of which is from the same landlord, and provide review over the forms including a signature to evidence review.
Responsible Official's Response: The Organization agrees with this finding and implemented changes before end of fiscal year.