Audit 32052

FY End
2022-06-30
Total Expended
$1.53M
Findings
8
Programs
2
Year: 2022 Accepted: 2023-06-05

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
36654 2022-002 Material Weakness Yes E
36655 2022-003 Significant Deficiency - N
36656 2022-002 Material Weakness Yes E
36657 2022-003 Significant Deficiency - N
613096 2022-002 Material Weakness Yes E
613097 2022-003 Significant Deficiency - N
613098 2022-002 Material Weakness Yes E
613099 2022-003 Significant Deficiency - N

Contacts

Name Title Type
N6DHY7ZC8719 Christopher Bathe Auditee
2155810743 Patrick Heavens Auditor
No contacts on file

Notes to SEFA

Title: Advance Accounting Policies: 1.Basis of PresentationThe accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Evesham Section 811 Housing Corporation (the Corporation) and is prepared using the accrual basis of accounting.2.Relationship to Basic Financial StatementsThe information in the 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 (Uniform Guidance). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. De Minimis Rate Used: N Rate Explanation: The Corporation has not elected to use the 10 percent de-minimis indirect cost rate as allowed under the Uniform Guidance. The Corporation had a capital advance with a balance of $1,402,500 at June 30, 2022 and 2021 with continuing compliance requirements.

Finding Details

Finding 2022-002: Tenant Eligibility - Material Weakness Repeat of prior year finding 2021-001 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, 2021 - June 30, 2022 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: None reported Condition/Context: We identified a lack review and maintenance of tenant file documentation for eligibility requirements including documentation of a signed lease, asset verification, income verification, medical expense support, and an accurate wait-list. Our population included all tenants. Two of two tenant files reviewed were missing required support. This was not a statistically valid sample. Cause: Lack of management oversight due to turnover. 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 30,2022. Recommendation: The Corporation should have procedures in place to ensure documentation is maintained accordance with its requirements.
Finding 2022-003: Required Monthly Deposits to the Replacement Reserve - Significant Deficiency 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, 2021 - June 30, 2022 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: None reported. Condition/Context: There was one month where required deposit was missed. Our sample included all 12 months of required deposits and therefore, the entire population was subject to testing. Effect: One month of deposit was 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 2022-002: Tenant Eligibility - Material Weakness Repeat of prior year finding 2021-001 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, 2021 - June 30, 2022 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: None reported Condition/Context: We identified a lack review and maintenance of tenant file documentation for eligibility requirements including documentation of a signed lease, asset verification, income verification, medical expense support, and an accurate wait-list. Our population included all tenants. Two of two tenant files reviewed were missing required support. This was not a statistically valid sample. Cause: Lack of management oversight due to turnover. 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 30,2022. Recommendation: The Corporation should have procedures in place to ensure documentation is maintained accordance with its requirements.
Finding 2022-003: Required Monthly Deposits to the Replacement Reserve - Significant Deficiency 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, 2021 - June 30, 2022 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: None reported. Condition/Context: There was one month where required deposit was missed. Our sample included all 12 months of required deposits and therefore, the entire population was subject to testing. Effect: One month of deposit was 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 2022-002: Tenant Eligibility - Material Weakness Repeat of prior year finding 2021-001 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, 2021 - June 30, 2022 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: None reported Condition/Context: We identified a lack review and maintenance of tenant file documentation for eligibility requirements including documentation of a signed lease, asset verification, income verification, medical expense support, and an accurate wait-list. Our population included all tenants. Two of two tenant files reviewed were missing required support. This was not a statistically valid sample. Cause: Lack of management oversight due to turnover. 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 30,2022. Recommendation: The Corporation should have procedures in place to ensure documentation is maintained accordance with its requirements.
Finding 2022-003: Required Monthly Deposits to the Replacement Reserve - Significant Deficiency 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, 2021 - June 30, 2022 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: None reported. Condition/Context: There was one month where required deposit was missed. Our sample included all 12 months of required deposits and therefore, the entire population was subject to testing. Effect: One month of deposit was 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 2022-002: Tenant Eligibility - Material Weakness Repeat of prior year finding 2021-001 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, 2021 - June 30, 2022 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: None reported Condition/Context: We identified a lack review and maintenance of tenant file documentation for eligibility requirements including documentation of a signed lease, asset verification, income verification, medical expense support, and an accurate wait-list. Our population included all tenants. Two of two tenant files reviewed were missing required support. This was not a statistically valid sample. Cause: Lack of management oversight due to turnover. 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 30,2022. Recommendation: The Corporation should have procedures in place to ensure documentation is maintained accordance with its requirements.
Finding 2022-003: Required Monthly Deposits to the Replacement Reserve - Significant Deficiency 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, 2021 - June 30, 2022 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: None reported. Condition/Context: There was one month where required deposit was missed. Our sample included all 12 months of required deposits and therefore, the entire population was subject to testing. Effect: One month of deposit was 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.