Audit 352915

Finding No. 2024-001 - Eligibility - Material Weakness Name of Federal Agency: The United States Department of Housing and Urban Development Federal Program Name: Section 8 Housing Assistance Payments Assistance Listing Number: 14.195 Federal Award Identification Number and Year: MD06L000037. Program year is 2024. Name of Pass-through Entity (if applicable): N/A Criteria According to 4-14.195-6 of Appendix XI to 2 CFR, Part 200 of the United States Office of Management and Budget, the Project must verify the eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility; (b) conducting verifications of family income and other pertinent information through third parties the use of HUD's Enterprise Income Verification (EIV) system in its entirety: (i) as a third-party source to verify tenant employment and income information during annual and streamlined reexaminations of family composition and income, and to reduce administrative and subsidy payment errors 24 CFR 5.233; (c) documenting inspections and tenant certifications; and (d) determining that the tenant income did not exceed the maximum limit set by HUD for the jurisdiction, as shown in HUD's published notice transmitting the Limited for Low-Income and Very Low-Income Families under the Housing Act of 1937. Additionally, project's must reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment as necessary. For both family income examinations and reexaminations, the Project must obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). For reexaminations, the Project must utilize the Form HUD-50059 worksheet and maintain the document in the tenant lease file (24 CFR section 208.104(a)(2) and 24 CFR section 208.108). Condition In a sample of 13 files tested, there were exceptions noted in 11 files. In 6 out of 13 files, the Project did not perform timely income verification using the EIV system and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not obtain tenant income verification and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not complete a HUD-50059 form timely as part of the annual recertification process and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not perform a move out inspection and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not properly refund tenant security deposits or maintain documentation for the refund. In 1 out of 13 files, the Project did not properly calculate the tenant subsidy rent. In 1 out of 13 files, the Project did not properly calculate the tenant portion of rent. In 7 out of 13 files, the Project did not correctly calculate tenant rents in accordance with HUD-92458. Cause The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with federal guidelines. Effect The Project is not in compliance with federal regulations regarding eligibility. The Housing Assistance Payment ("HAP") calculation may be inaccurate resulting in an underpayment or overpayment of HAP. Additionally, ineligible applicants may be approved for tenancy. Questioned Costs N/A Context A sample of 13 tenant files were selected from a population of 118. We identified exceptions in 11 out of the 13 files tested. The sample was not statistically valid. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that management reviews its internal controls over obtaining and maintaining tenant file documentation to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by federal regulations.

Finding No. 2024-002 - Special Tests and Provisions - Material Weakness Name of Federal Agency: The United States Department of Housing and Urban Development Federal Program Name: Section 8 Housing Assistance Payments Assistance Listing Number: 14.195 Federal Award Identification Number and Year: MD06L000037. Program year is 2024. Name of Pass-through Entity (if applicable): N/A Criteria According to 4-14.195-11 of Appendix XI to 2 CFR, Part 200 of the United States Office of Management and Budget, the Project must reduce claims for assistance on vacant units under certain circumstances. Condition In a sample of 6 move out tenant files tested, there were exceptions noted in 6 files. In 6 out of 6 files, the Project did not maintain appropriate documentation to support the move-out and it could not be determined if move out procedures were performed in accordance with HUD. Cause The Project failed to follow the policies and procedures which have been established for proper move out procedures and tenant file maintenance. Effect The Project is not in compliance with federal regulations regarding special tests and provisions. The HAP calculation may be inaccurate resulting in an underpayment or overpayment of HAP. Questioned Costs N/A Context A sample of 6 move out tenants were selected from a population of 22. We identified exceptions in 6 out of 6 move out tenants tested. The sample was not statistically valid. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that management reviews its internal controls over obtaining and maintaining tenant file documentation to ensure compliance with special test and provision requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the procedures around move out tenants are in accordance with guidelines specified by federal regulations.

Finding No. 2024-001 - Eligibility - Material Weakness Name of Federal Agency: The United States Department of Housing and Urban Development Federal Program Name: Section 8 Housing Assistance Payments Assistance Listing Number: 14.195 Federal Award Identification Number and Year: MD06L000037. Program year is 2024. Name of Pass-through Entity (if applicable): N/A Criteria According to 4-14.195-6 of Appendix XI to 2 CFR, Part 200 of the United States Office of Management and Budget, the Project must verify the eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility; (b) conducting verifications of family income and other pertinent information through third parties the use of HUD's Enterprise Income Verification (EIV) system in its entirety: (i) as a third-party source to verify tenant employment and income information during annual and streamlined reexaminations of family composition and income, and to reduce administrative and subsidy payment errors 24 CFR 5.233; (c) documenting inspections and tenant certifications; and (d) determining that the tenant income did not exceed the maximum limit set by HUD for the jurisdiction, as shown in HUD's published notice transmitting the Limited for Low-Income and Very Low-Income Families under the Housing Act of 1937. Additionally, project's must reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment as necessary. For both family income examinations and reexaminations, the Project must obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). For reexaminations, the Project must utilize the Form HUD-50059 worksheet and maintain the document in the tenant lease file (24 CFR section 208.104(a)(2) and 24 CFR section 208.108). Condition In a sample of 13 files tested, there were exceptions noted in 11 files. In 6 out of 13 files, the Project did not perform timely income verification using the EIV system and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not obtain tenant income verification and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not complete a HUD-50059 form timely as part of the annual recertification process and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not perform a move out inspection and this data was not maintained in the lease file. In 3 out of 13 files, the Project did not properly refund tenant security deposits or maintain documentation for the refund. In 1 out of 13 files, the Project did not properly calculate the tenant subsidy rent. In 1 out of 13 files, the Project did not properly calculate the tenant portion of rent. In 7 out of 13 files, the Project did not correctly calculate tenant rents in accordance with HUD-92458. Cause The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with federal guidelines. Effect The Project is not in compliance with federal regulations regarding eligibility. The Housing Assistance Payment ("HAP") calculation may be inaccurate resulting in an underpayment or overpayment of HAP. Additionally, ineligible applicants may be approved for tenancy. Questioned Costs N/A Context A sample of 13 tenant files were selected from a population of 118. We identified exceptions in 11 out of the 13 files tested. The sample was not statistically valid. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that management reviews its internal controls over obtaining and maintaining tenant file documentation to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by federal regulations.

Finding No. 2024-002 - Special Tests and Provisions - Material Weakness Name of Federal Agency: The United States Department of Housing and Urban Development Federal Program Name: Section 8 Housing Assistance Payments Assistance Listing Number: 14.195 Federal Award Identification Number and Year: MD06L000037. Program year is 2024. Name of Pass-through Entity (if applicable): N/A Criteria According to 4-14.195-11 of Appendix XI to 2 CFR, Part 200 of the United States Office of Management and Budget, the Project must reduce claims for assistance on vacant units under certain circumstances. Condition In a sample of 6 move out tenant files tested, there were exceptions noted in 6 files. In 6 out of 6 files, the Project did not maintain appropriate documentation to support the move-out and it could not be determined if move out procedures were performed in accordance with HUD. Cause The Project failed to follow the policies and procedures which have been established for proper move out procedures and tenant file maintenance. Effect The Project is not in compliance with federal regulations regarding special tests and provisions. The HAP calculation may be inaccurate resulting in an underpayment or overpayment of HAP. Questioned Costs N/A Context A sample of 6 move out tenants were selected from a population of 22. We identified exceptions in 6 out of 6 move out tenants tested. The sample was not statistically valid. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that management reviews its internal controls over obtaining and maintaining tenant file documentation to ensure compliance with special test and provision requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the procedures around move out tenants are in accordance with guidelines specified by federal regulations.