Audit 400933

Finding No. 2025-001 - E - Eligibility for Uniform Guidance - Significant Deficiency Name of Federal Agency: Department of Housing and Urban Development Federal Program Name: Supportive Housing For The Elderly Assistance Listing Number: 14.157 Federal Award Identification Number and Year: 126EE030, program year 2023. 126-EE030, program year 2001 Name of Pass-Through Entity (if applicable): Not Applicable 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: -one out of three tenants' income verification was not performed at all with the use of the HUD Enterprise Income Verification ("EIV"). -one out of two tenants' recertifications were not 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 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 tested did not have an EIV performed timely and one out of two tenants' recertifications were not performed timely. Auditor Noncompliance Code: Z-Other for REAC filing Identification as a Repeat Finding: Yes, 2024-001 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that EIVs are performed timely, 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. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions: REACH has policies in place to complete EIVs and recertifications 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 2025. In 2026 property management will be outsourced to a third party management company to address outstanding compliance issues.

Finding No. 2025-002 - N - Special Tests and Provisions for Uniform Guidance - Significant Deficiency Name of Federal Agency: Department of Housing and Urban Development Federal Program Name: Supportive Housing For The Elderly Assistance Listing Number: 14.157 Federal Award Identification Number and Year: 126EE030, program year 2023. 126-EE030, program year 2001 Name of Pass-Through Entity (if applicable): Not Applicable Criteria: In accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs, within 30 days after the move-out date (or shorter time if required by state and/or local laws), management must either: refund the full security deposit plus accrued interest to a tenant that does not owe any amounts under the lease; or provide the tenant with an itemized list of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of the tenant's rights under state and local laws. Condition: In connection with the procedures applied to a sample of one tenant that moved out of the project during the year, we noted one instance where management failed to refund the tenant security deposit and/or provide the tenant with an itemized list of charges deducted from the deposit within thirty days after the move-out date. Cause: Management's policies with respect to move outs and security deposit refunds were not consistently followed. Effect or Potential Effect: Management failed to comply with the HUD occupancy requirement to timely refund the tenant security deposits or to provide the tenant with a list of charges. Questioned Costs: N/A Context: One move out tenant tested did not have their security deposit refund returned timely. Auditor Noncompliance Code: M - Security Deposits for REAC filing Identification as a Repeat Finding: Yes, 2024-002 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that move out inspections are performed timely, security deposits are returned timely and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Program. Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions: REACH has policies in place to return security deposits in a timely manner but was slightly delayed in issuing the security deposit refund for this unit. Management reviewed with the teams to ensure rent refunds would be processed within 30 days.

Finding No. 2025-003 - N - Special Tests and Provisions for Uniform Guidance - Significant Deficiency Name of Federal Agency: Department of Housing and Urban Development Federal Program Name: Supportive Housing For The Elderly Assistance Listing Number: 14.157 Federal Award Identification Number and Year: 126EE030, program year 2023. 126-EE030, program year 2001 Name of Pass-Through Entity (if applicable): Not Applicable 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: During the procedures applied to a sample of one tenant lease file, we noted the following instance of noncompliance with HUD regulations regarding tenant eligibility and the maintenance of lease files. One instance where the project did not maintain move in inspection form in the lease file. Cause: Management’s policies with respect to the determination of tenant security deposits 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 security deposits and 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 new tenant lease file tested did not have a move in inspection. Auditor Noncompliance Code: Z-Other for REAC filing Identification as a Repeat Finding: No Recommendation: 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 HUD. Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions: REACH has policies in place to complete move in inspections but due to tenant noncompliance and staffing issues this inspection was missed. Management scheduled training with staff in March 2026.