Audit 323747

FY End
2024-05-31
Total Expended
$2.04M
Findings
2
Programs
2
Organization: B.r.l Housing Corporation (OH)
Year: 2024 Accepted: 2024-10-03

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
501692 2024-001 Significant Deficiency - E
1078134 2024-001 Significant Deficiency - E

Contacts

Name Title Type
JNUSKX6UGHF8 Charley Hinkle Auditee
3303768787 John R Wright Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditure are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The entity has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditure of Federal Awards includes the federal award activity of B.R.L. Housing for the Elderly, Project No. 04211114 and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements of Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the Project, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Project.
Title: Loan Balance Outstanding Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditure are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The entity has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. The outstanding loan balance for the Mortgage Program for the Purchase or Refinancing of Existing Multifamily Housing Projects – Section 207/223(f) – ALN #14.155 was $1,739,735 as of May 31, 2024

Finding Details

Criteria: HUD regulations states the following: a. 24 CFR 5.230(a) Required consent by assistance applicants and participants. Each member of the family of an assistance applicant or participant who is at least 18 years of age, and each family head and spouse regardless of age, shall sign one or more consent forms. b. 24 CFR 891.410(b). The Owner must accept applications for admission to the project in the form prescribed by HUD is obligated to confirm all information provided by applicant families on the application. Applicant households applying for assisted units must complete a certification of eligibility as part of the application for admission. Applicant households must meet the disclosure and verification requirements for Social Security Numbers. Applicant families must sign and submit consent forms for the obtaining of wage and claim information from State Wage Information Collection Agencies. Both the Owner and the applicant household must complete and sign the application for admission. On request, the Owner must furnish copies of all applications for admission to HUD. c. 24 CFR 886.318 (a) The owner shall be responsible for the management and maintenance of the project in accordance with requirements established by HUD. These responsibilities shall include but not be limited to: Performance of all management functions, including the taking of applications; determining eligibility of applicants; selection of families, including verification of income, obtaining and verifying Social Security Numbers submitted by applicants, obtaining signed consent forms from applicants for the obtaining of wage and claim information from State Wage Information Collection Agencies and other pertinent requirements; and determination of the amount of tenant rent in accordance with HUD established schedules and criteria. Condition: The auditors selected 10 tenant samples from the rent roll and inspected their corresponding folders. Inspections revealed that 1 tenant's folder is missing signatures on the following documents: HUD 9887, EIV, and recertification. Cause of Condition: This condition arises from not strictly adhering to the provisions outlined in 24 CFR 5.230 (a), 24 CFR 891.410 (b), and 24 CFR 886.318 (a). Potential Effect of Condition: Not following the above guidance may cause several effects such as (a) Non-Compliance Issues – Failure to obtain required signatures on consent forms may result in non-compliance with HUD Regulations, which could lead to penalties or sanctions against housing provider. (b) Inaccurate Eligibility Determination – Without proper consent, the housing provider might not be able to verify critical information, such as income or Social Security Numbers, potentially leading to incorrect eligibility determinations for housing assistance. Questioned Costs: The auditors have identified questioned costs of $8,432 for annual rental subsidies. These questioned costs pertain only to the sample tested. Reporting Views of Responsible Officials: The responsible officials agree with the findings and recommendations and will adhere to the corrective action plan. Context: Tenants must remain in full compliance with the documentary requirements set forth by HUD, as outlined in their regulations. Failure to meet these requirements may result in non_x0002_compliance findings, which can impact program eligibility and participation. During the year, we have noted that 1 tenant's folder with missing signature on HUD 9887, EIV, and recertification. Recommendation: To ensure compliance, the auditors recommend the Project to (a) Develop a checklist to ensure that all required consent forms are signed by every eligible household member and that these forms are collected at the time of application or recertification. (b) Clearly inform applicants about the need for signatures on consent forms during the application process, provide assistance if they have questions or need help with completing the forms. ( c) Ensure proper documentation and retention of signed consent forms as per HUD requirements and internal policies, maintaining records for the appropriate duration. (d) Train staff in the importance of obtaining all necessary signatures and on the specific consent forms required. Ensure they understand the implications of non-compliance. Management’s Response: To prevent similar occurrences in the future, we will continue our efforts to have a robust monitoring and review process and improve our coordination with the tenants. We will explore alternative methods to ensure the HUD documentation is completed as required.
Criteria: HUD regulations states the following: a. 24 CFR 5.230(a) Required consent by assistance applicants and participants. Each member of the family of an assistance applicant or participant who is at least 18 years of age, and each family head and spouse regardless of age, shall sign one or more consent forms. b. 24 CFR 891.410(b). The Owner must accept applications for admission to the project in the form prescribed by HUD is obligated to confirm all information provided by applicant families on the application. Applicant households applying for assisted units must complete a certification of eligibility as part of the application for admission. Applicant households must meet the disclosure and verification requirements for Social Security Numbers. Applicant families must sign and submit consent forms for the obtaining of wage and claim information from State Wage Information Collection Agencies. Both the Owner and the applicant household must complete and sign the application for admission. On request, the Owner must furnish copies of all applications for admission to HUD. c. 24 CFR 886.318 (a) The owner shall be responsible for the management and maintenance of the project in accordance with requirements established by HUD. These responsibilities shall include but not be limited to: Performance of all management functions, including the taking of applications; determining eligibility of applicants; selection of families, including verification of income, obtaining and verifying Social Security Numbers submitted by applicants, obtaining signed consent forms from applicants for the obtaining of wage and claim information from State Wage Information Collection Agencies and other pertinent requirements; and determination of the amount of tenant rent in accordance with HUD established schedules and criteria. Condition: The auditors selected 10 tenant samples from the rent roll and inspected their corresponding folders. Inspections revealed that 1 tenant's folder is missing signatures on the following documents: HUD 9887, EIV, and recertification. Cause of Condition: This condition arises from not strictly adhering to the provisions outlined in 24 CFR 5.230 (a), 24 CFR 891.410 (b), and 24 CFR 886.318 (a). Potential Effect of Condition: Not following the above guidance may cause several effects such as (a) Non-Compliance Issues – Failure to obtain required signatures on consent forms may result in non-compliance with HUD Regulations, which could lead to penalties or sanctions against housing provider. (b) Inaccurate Eligibility Determination – Without proper consent, the housing provider might not be able to verify critical information, such as income or Social Security Numbers, potentially leading to incorrect eligibility determinations for housing assistance. Questioned Costs: The auditors have identified questioned costs of $8,432 for annual rental subsidies. These questioned costs pertain only to the sample tested. Reporting Views of Responsible Officials: The responsible officials agree with the findings and recommendations and will adhere to the corrective action plan. Context: Tenants must remain in full compliance with the documentary requirements set forth by HUD, as outlined in their regulations. Failure to meet these requirements may result in non_x0002_compliance findings, which can impact program eligibility and participation. During the year, we have noted that 1 tenant's folder with missing signature on HUD 9887, EIV, and recertification. Recommendation: To ensure compliance, the auditors recommend the Project to (a) Develop a checklist to ensure that all required consent forms are signed by every eligible household member and that these forms are collected at the time of application or recertification. (b) Clearly inform applicants about the need for signatures on consent forms during the application process, provide assistance if they have questions or need help with completing the forms. ( c) Ensure proper documentation and retention of signed consent forms as per HUD requirements and internal policies, maintaining records for the appropriate duration. (d) Train staff in the importance of obtaining all necessary signatures and on the specific consent forms required. Ensure they understand the implications of non-compliance. Management’s Response: To prevent similar occurrences in the future, we will continue our efforts to have a robust monitoring and review process and improve our coordination with the tenants. We will explore alternative methods to ensure the HUD documentation is completed as required.