Audit 36267

FY End
2022-12-31
Total Expended
$2.17M
Findings
6
Programs
2
Organization: Community Housing, Inc. (OR)
Year: 2022 Accepted: 2023-04-26
Auditor: Cohnreznick LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
34527 2022-001 Significant Deficiency Yes E
34528 2022-003 Significant Deficiency - N
34529 2022-002 Significant Deficiency Yes E
610969 2022-001 Significant Deficiency Yes E
610970 2022-003 Significant Deficiency - N
610971 2022-002 Significant Deficiency Yes E

Programs

ALN Program Spent Major Findings
14.157 Supportive Housing for the Elderly $1.42M Yes 2
14.239 Home Investment Partnerships Program $750,000 Yes 1

Contacts

Name Title Type
L9NEKD325FX5 Daniel Valliere Auditee
5032363429 Karen Smith Auditor
No contacts on file

Notes to SEFA

Title: Note 3 - U.S. Department of Housing and Urban Development loan program Accounting Policies: Note 1 - Basis of presentationThe accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal award activity of Community Housing, Inc. (the "Company") under programs of the federal government for the year ended December 31, 2022. The information in this 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"). Because the Schedule presents only a selected portion of the operations of the Company, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Company. De Minimis Rate Used: N Rate Explanation: Note 2 - Summary of significant accounting policiesExpenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in OMB Circular A122, "Cost Principles for Non-Profit Organizations" and the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Community Housing Inc. has not elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Community Housing Inc. has received U.S. Department of Housing and Urban Development direct loans under Section 202 of the National Housing Act and the Home Investment Partnership Program. The loan balances outstanding at the beginning of the year are included in the federal expenditures presented in the Schedule. Community Housing Inc. received no additional loans during the year ended December 31, 2022. The balance of the loans outstanding at December 31, 2022 consists of: 14.157 Section 202 Capital Advance Mortgage Program $1,296,900, 14.239 Home Investment Partnership Program $750,000.

Finding Details

U.S. Department of Housing and Urban Development - Supportive Housing for the Elderly (Section 202) Program and Home Investment Partnership Program Finding No. 2022-001; Federal Assistance Listing Number 14.157; Finding No. 2022-002; and Federal Assistance Listing Number 14.239 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs Condition In connection with our lease file review, we noted that: 1. One out of three tenants? recertification was not performed timely; and 2. One out of three tenants? income verification was not performed timely with the use of the HUD Enterprise Income Verification ("EIV") timeliness. Cause Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant recertification eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs N/A Context One out of three tenants' recertification was not performed timely, and one out of three tenants tested did not have the EIV run timely Identification as a Repeat Finding Yes Recommendation Management should establish procedures and monitor compliance with those procedures to insure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: E-Eligibility for Uniform Guidance; Z-Other Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions: Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely and will be providing ongoing training and guidance to staff to make sure the policies are being followed.
Finding No. 2022-003; Federal Assistance Listing Number 14.157 Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times a fully funded separate bank account for tenant security deposits collected. Condition As of December 31, 2022 management has not fully funded the tenant security deposits cash account. The tenant security deposits cash account was underfunded by $1,142 Cause The tenant security deposits liability exceeds the tenant security deposits cash account by $1,142 as of December 31, 2022.. Effect or Potential Effect Management commingled tenant security deposits with its operating cash and did not have sufficient cash balance in the tenant security deposits cash account to cover the tenant security deposits liability as of December 31, 2022. Questioned Costs N/A Context Security deposit account is underfunded by $1,142. Identification as a Repeat Finding No Recommendation Management should transfer $1,142 from the operating account in order to fully fund the tenant security deposits account. Auditor Noncompliance Code: N-Special tests and provisions for Uniform Guidance; M-Security deposits Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions: The difference of $1,142 primarily relates to what is showing as delinquent security deposits. Upon further review, Fiscal discovered that $402 of one tenant?s and $269 of another tenant?s security deposits were duplicated. The community manager will do a ledger adjustment for these instances. A third tenant?s deposit was never collected in 2019 and $323 of this deposit is to be reversed. Only $353 is truly outstanding. Fiscal asked the Maples I community manager to attempt to collect $303 SD ($353 less $50 paid) in 2023. Going forward, security deposits receivable will be reviewed monthly. Fiscal will work with property management department to notify them if a security deposit is outstanding after a tenant has moved in.
U.S. Department of Housing and Urban Development - Supportive Housing for the Elderly (Section 202) Program and Home Investment Partnership Program Finding No. 2022-001; Federal Assistance Listing Number 14.157; Finding No. 2022-002; and Federal Assistance Listing Number 14.239 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs Condition In connection with our lease file review, we noted that: 1. One out of three tenants? recertification was not performed timely; and 2. One out of three tenants? income verification was not performed timely with the use of the HUD Enterprise Income Verification ("EIV") timeliness. Cause Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant recertification eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs N/A Context One out of three tenants' recertification was not performed timely, and one out of three tenants tested did not have the EIV run timely Identification as a Repeat Finding Yes Recommendation Management should establish procedures and monitor compliance with those procedures to insure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: E-Eligibility for Uniform Guidance; Z-Other Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions: Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely and will be providing ongoing training and guidance to staff to make sure the policies are being followed.
U.S. Department of Housing and Urban Development - Supportive Housing for the Elderly (Section 202) Program and Home Investment Partnership Program Finding No. 2022-001; Federal Assistance Listing Number 14.157; Finding No. 2022-002; and Federal Assistance Listing Number 14.239 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs Condition In connection with our lease file review, we noted that: 1. One out of three tenants? recertification was not performed timely; and 2. One out of three tenants? income verification was not performed timely with the use of the HUD Enterprise Income Verification ("EIV") timeliness. Cause Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant recertification eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs N/A Context One out of three tenants' recertification was not performed timely, and one out of three tenants tested did not have the EIV run timely Identification as a Repeat Finding Yes Recommendation Management should establish procedures and monitor compliance with those procedures to insure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: E-Eligibility for Uniform Guidance; Z-Other Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions: Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely and will be providing ongoing training and guidance to staff to make sure the policies are being followed.
Finding No. 2022-003; Federal Assistance Listing Number 14.157 Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, HUD projects are required to establish and maintain at all times a fully funded separate bank account for tenant security deposits collected. Condition As of December 31, 2022 management has not fully funded the tenant security deposits cash account. The tenant security deposits cash account was underfunded by $1,142 Cause The tenant security deposits liability exceeds the tenant security deposits cash account by $1,142 as of December 31, 2022.. Effect or Potential Effect Management commingled tenant security deposits with its operating cash and did not have sufficient cash balance in the tenant security deposits cash account to cover the tenant security deposits liability as of December 31, 2022. Questioned Costs N/A Context Security deposit account is underfunded by $1,142. Identification as a Repeat Finding No Recommendation Management should transfer $1,142 from the operating account in order to fully fund the tenant security deposits account. Auditor Noncompliance Code: N-Special tests and provisions for Uniform Guidance; M-Security deposits Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions: The difference of $1,142 primarily relates to what is showing as delinquent security deposits. Upon further review, Fiscal discovered that $402 of one tenant?s and $269 of another tenant?s security deposits were duplicated. The community manager will do a ledger adjustment for these instances. A third tenant?s deposit was never collected in 2019 and $323 of this deposit is to be reversed. Only $353 is truly outstanding. Fiscal asked the Maples I community manager to attempt to collect $303 SD ($353 less $50 paid) in 2023. Going forward, security deposits receivable will be reviewed monthly. Fiscal will work with property management department to notify them if a security deposit is outstanding after a tenant has moved in.
U.S. Department of Housing and Urban Development - Supportive Housing for the Elderly (Section 202) Program and Home Investment Partnership Program Finding No. 2022-001; Federal Assistance Listing Number 14.157; Finding No. 2022-002; and Federal Assistance Listing Number 14.239 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs Condition In connection with our lease file review, we noted that: 1. One out of three tenants? recertification was not performed timely; and 2. One out of three tenants? income verification was not performed timely with the use of the HUD Enterprise Income Verification ("EIV") timeliness. Cause Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant recertification eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs N/A Context One out of three tenants' recertification was not performed timely, and one out of three tenants tested did not have the EIV run timely Identification as a Repeat Finding Yes Recommendation Management should establish procedures and monitor compliance with those procedures to insure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: E-Eligibility for Uniform Guidance; Z-Other Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions: Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely and will be providing ongoing training and guidance to staff to make sure the policies are being followed.