Audit 364594

FY End
2024-12-31
Total Expended
$3.22M
Findings
8
Programs
2
Year: 2024 Accepted: 2025-08-20
Auditor: Cohnreznick LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
574010 2024-001 Significant Deficiency Yes E
574011 2024-002 Significant Deficiency - E
574012 2024-001 Significant Deficiency Yes E
574013 2024-002 Significant Deficiency - E
1150452 2024-001 Significant Deficiency Yes E
1150453 2024-002 Significant Deficiency - E
1150454 2024-001 Significant Deficiency Yes E
1150455 2024-002 Significant Deficiency - E

Programs

ALN Program Spent Major Findings
14.157 Supportive Housing for the Elderly $110,230 Yes 2
14.239 Home Investment Partnerships Program $42,238 - 0

Contacts

Name Title Type
NVP8F3CP3NK1 Margaret Salazar Auditee
5032310682 Brian Martin Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - Basis of Presentation Accounting Policies: Expenditures 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 A-122, "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 III, Inc. has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Community Housing III, Inc. has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal award activity of Community Housing III, Inc., (the "Company") under programs of the federal government for the year ended December 31, 2024. 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 Community Housing III, Inc., it is not intended to and does not present the financial position, changes in net assets, or cash flows of Community Housing III, Inc.
Title: Note 2 - Summary of Significant Accounting Policies Accounting Policies: Expenditures 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 A-122, "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 III, Inc. has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Community Housing III, Inc. has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures 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 A-122, "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 III, Inc. has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: Note 3 - U.S. Department of Housing and Urban Development Loan Program Accounting Policies: Expenditures 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 A-122, "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 III, Inc. has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Community Housing III, Inc. has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Community Housing III, Inc. has received U.S. Department of Housing and Urban Development loans under Section 202. The loan balances outstanding at the beginning of the year are included in the federal expenditures presented in the Schedule. Community Housing III, Inc. received no additional loans during the year ended December 31, 2024. The balance of the loans outstanding at December 31, 2024 consists of: Federal Assistance Listing Number Program Name Balance 14.157 Supportive Housing for the Elderly $ 3 ,065,900 14.239 HOME Investment Partnership Program 4 2,238 $ 3 ,108,138

Finding Details

Finding No. 2024-001; Federal Assistance Listing Number 14.157 Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted: • one out of four tenants did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. • an additional one out of four tenants did not have income verification with the use of EIV at all. • one out of three tenant files tested did not have a timely recertification performed. • one out of one new tenant lease files tested did not have a move-in inspection. • one out of one new tenant lease files tested did not have an initial certification performed timely. 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 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. Context One out of four tenants tested in a population of 31 did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. One out of four tenants tested in a population of 31 did not have income verification with the use of the EIV performed at all. One out of three tenant files tested did not have a timely recertification performed, but the tenant was determined eligible. One out of one new tenant lease file tested did not have a move-in inspection. One out of one new tenant lease file tested did not have the initial certification performed timely. Repeat Finding Yes, 2023-001 Questioned Costs N/A Recommendation Management should establish procedures and monitor compliance with those procedures to insure that EIVs and recertifications are performed timely, inspections are completed, waitlists are being completed and followed, 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: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2024. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157 Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, management is required to admit applicants in the proper order from the wait list and to document proper admission and denial procedures. Condition Management did not select applicants from the wait list in the correct order. Cause No procedures were in place to ensure that applicants were admitted in the proper order from the wait list. Effect or Potential Effect Tenants were not admitted in accordance with HUD guidelines. Context One out of one new tenant lease files tested did not appear on the waitlist and others were on list before this one new move-in. Repeat Finding No Questioned Costs N/A Recommendation Management should establish procedures to admit applicants in order of wait list priority and document all applicants admitted and denied in accordance with HUD guidelines. Auditor Noncompliance Code: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to admit applicants in the order of their waitlist priority. Management works with on-site property staff and provides training on the prioritization of wait list applicants. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance with required regulations.
Finding No. 2024-001; Federal Assistance Listing Number 14.157 Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted: • one out of four tenants did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. • an additional one out of four tenants did not have income verification with the use of EIV at all. • one out of three tenant files tested did not have a timely recertification performed. • one out of one new tenant lease files tested did not have a move-in inspection. • one out of one new tenant lease files tested did not have an initial certification performed timely. 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 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. Context One out of four tenants tested in a population of 31 did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. One out of four tenants tested in a population of 31 did not have income verification with the use of the EIV performed at all. One out of three tenant files tested did not have a timely recertification performed, but the tenant was determined eligible. One out of one new tenant lease file tested did not have a move-in inspection. One out of one new tenant lease file tested did not have the initial certification performed timely. Repeat Finding Yes, 2023-001 Questioned Costs N/A Recommendation Management should establish procedures and monitor compliance with those procedures to insure that EIVs and recertifications are performed timely, inspections are completed, waitlists are being completed and followed, 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: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2024. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157 Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, management is required to admit applicants in the proper order from the wait list and to document proper admission and denial procedures. Condition Management did not select applicants from the wait list in the correct order. Cause No procedures were in place to ensure that applicants were admitted in the proper order from the wait list. Effect or Potential Effect Tenants were not admitted in accordance with HUD guidelines. Context One out of one new tenant lease files tested did not appear on the waitlist and others were on list before this one new move-in. Repeat Finding No Questioned Costs N/A Recommendation Management should establish procedures to admit applicants in order of wait list priority and document all applicants admitted and denied in accordance with HUD guidelines. Auditor Noncompliance Code: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to admit applicants in the order of their waitlist priority. Management works with on-site property staff and provides training on the prioritization of wait list applicants. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance with required regulations.
Finding No. 2024-001; Federal Assistance Listing Number 14.157 Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted: • one out of four tenants did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. • an additional one out of four tenants did not have income verification with the use of EIV at all. • one out of three tenant files tested did not have a timely recertification performed. • one out of one new tenant lease files tested did not have a move-in inspection. • one out of one new tenant lease files tested did not have an initial certification performed timely. 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 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. Context One out of four tenants tested in a population of 31 did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. One out of four tenants tested in a population of 31 did not have income verification with the use of the EIV performed at all. One out of three tenant files tested did not have a timely recertification performed, but the tenant was determined eligible. One out of one new tenant lease file tested did not have a move-in inspection. One out of one new tenant lease file tested did not have the initial certification performed timely. Repeat Finding Yes, 2023-001 Questioned Costs N/A Recommendation Management should establish procedures and monitor compliance with those procedures to insure that EIVs and recertifications are performed timely, inspections are completed, waitlists are being completed and followed, 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: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2024. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157 Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, management is required to admit applicants in the proper order from the wait list and to document proper admission and denial procedures. Condition Management did not select applicants from the wait list in the correct order. Cause No procedures were in place to ensure that applicants were admitted in the proper order from the wait list. Effect or Potential Effect Tenants were not admitted in accordance with HUD guidelines. Context One out of one new tenant lease files tested did not appear on the waitlist and others were on list before this one new move-in. Repeat Finding No Questioned Costs N/A Recommendation Management should establish procedures to admit applicants in order of wait list priority and document all applicants admitted and denied in accordance with HUD guidelines. Auditor Noncompliance Code: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to admit applicants in the order of their waitlist priority. Management works with on-site property staff and provides training on the prioritization of wait list applicants. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance with required regulations.
Finding No. 2024-001; Federal Assistance Listing Number 14.157 Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted: • one out of four tenants did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. • an additional one out of four tenants did not have income verification with the use of EIV at all. • one out of three tenant files tested did not have a timely recertification performed. • one out of one new tenant lease files tested did not have a move-in inspection. • one out of one new tenant lease files tested did not have an initial certification performed timely. 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 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. Context One out of four tenants tested in a population of 31 did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. One out of four tenants tested in a population of 31 did not have income verification with the use of the EIV performed at all. One out of three tenant files tested did not have a timely recertification performed, but the tenant was determined eligible. One out of one new tenant lease file tested did not have a move-in inspection. One out of one new tenant lease file tested did not have the initial certification performed timely. Repeat Finding Yes, 2023-001 Questioned Costs N/A Recommendation Management should establish procedures and monitor compliance with those procedures to insure that EIVs and recertifications are performed timely, inspections are completed, waitlists are being completed and followed, 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: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2024. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.
Finding No. 2024-002; Federal Assistance Listing Number 14.157 Criteria In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, management is required to admit applicants in the proper order from the wait list and to document proper admission and denial procedures. Condition Management did not select applicants from the wait list in the correct order. Cause No procedures were in place to ensure that applicants were admitted in the proper order from the wait list. Effect or Potential Effect Tenants were not admitted in accordance with HUD guidelines. Context One out of one new tenant lease files tested did not appear on the waitlist and others were on list before this one new move-in. Repeat Finding No Questioned Costs N/A Recommendation Management should establish procedures to admit applicants in order of wait list priority and document all applicants admitted and denied in accordance with HUD guidelines. Auditor Noncompliance Code: R-Section 8 program administration. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions REACH has policies in place to admit applicants in the order of their waitlist priority. Management works with on-site property staff and provides training on the prioritization of wait list applicants. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance with required regulations.