Audit 43339

FY End
2022-06-30
Total Expended
$6.25M
Findings
8
Programs
2
Organization: Gulf Coast Heron Housing, INC (FL)
Year: 2022 Accepted: 2023-01-31
Auditor: Rsm US LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
49884 2022-001 Material Weakness - E
49885 2022-002 - Yes N
49886 2022-001 Material Weakness - E
49887 2022-002 - Yes N
626326 2022-001 Material Weakness - E
626327 2022-002 - Yes N
626328 2022-001 Material Weakness - E
626329 2022-002 - Yes N

Programs

ALN Program Spent Major Findings
14.157 Supportive Housing for the Elderly $5.69M Yes 2
14.195 Section 8 Housing Assistance Payments Program $560,191 Yes 2

Contacts

Name Title Type
ESMAD1PQ6FL4 Paul Dennison Auditee
7274791800 Bo Brault Auditor
No contacts on file

Notes to SEFA

Title: Loan/loan guarantee outstanding balances 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 the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Project had the following loan balances at June 30, 2022:Assistance Listing Number 14.157; Description: Supportive Housing for the Elderly Section 202 Direct Loan; Original Loan Amount: $5,693,300; Balance at July 1, 2021: $ 5,693,300; Additional Loan Funding (Payments Made):$ - ; Balance at June 30, 2022:$ 5,693,300
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 the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of Gulf Coast Heron Housing, Inc. under programs of the federal government for the year ended June 30, 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 this Schedule presents only a selected portion of the operations of Gulf Coast Heron Housing, Inc., it is not intended to and does not present the financial position, changes in net assets, or cash flows of Gulf Coast Heron Housing, Inc.Some amounts presented in the schedule may differ from amounts presented or used in the preparation of the financial statements.

Finding Details

Criteria: Based on principles and guidance contained within the 2013 Internal Control?Integrated Framework as published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), management is responsible for the design, implementation and maintenance of internal controls over financial reporting with the objective that the financial statements are accurate under U.S. GAAP. As it relates to Assistance Listing Number 14.157 Supportive Housing for the Elderly (Section 202) Uniform Guidance requires that the owner is responsible for annually reexamining incomes of households occupying assisted units and making appropriate adjustments to the tenant payment and the project rental assistance payment in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 891.410(g)- Reexamination of household family income and composition - (1) Regular reexaminations. The Owner must reexamine the income and composition of the household at least every 12 months. Upon verification of the information, the Owner must make appropriate adjustments in the total tenant payment and must determine whether the household's unit size is still appropriate. The Owner must adjust tenant payment and the project rental assistance payment, and must carry out any unit transfer in accordance with HUD standards. As it relates to Assistance Listing Number 14.195 Section 8 Housing Assistance Payments Program Uniform Guidance requires that the Project reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment, as necessary in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 880.603(c)- Reexamination of family income and composition - (1) Regular reexaminations. The owner must reexamine the income and composition of all families at least every 12 months. After consultation with the family and upon verification of the information, the owner must make appropriate adjustments in the Total Tenant Payment in accordance with part 5 of this title and determine whether the family's unit size is still appropriate. The owner must adjust Tenant Rent and the Housing Assistance Payment to reflect any change in Total Tenant Payment and must carry out any unit transfer required by HUD. Condition: During our review of eligibility testing support, we noted that for the tenant?s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner?s Certification and Application for Housing Assistance Payments (HAP) for eight months of fiscal year 2022. Upon the Project?s analysis, it was determined that the total amount of the error, net of vacancies, was $37,585. Context: It was noted that the Project collected more money each month from HUD as a result of incorrectly including the utility allowance as part of the contract rent for eight months of fiscal year 2022. Effect: Incorrect rates were utilized to calculate the project tenant rental assistance payments. These incorrect rates were paid by HUD to the Project resulting in an overpayment of funds in the amount of $37,585. Cause: The Project relies heavily on a few key individuals to perform review of the tenant certifications and re-examinations. While this process of review did occur, the incorrect rents approved went undetected during the Project?s internal review process. Recommendation: We recommend that the Project establish procedures to ensure that there is a better process to check the amounts of contract rent being approved on the reexaminations and certifications of tenants. Additionally, we recommend that the monthly HAP forms are more closely reviewed by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan
Other Matter Compliance Criteria: Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 A). All disbursements from the reserve must be approved by HUD (24 CFR sections 891.405 and 891.605). Condition: During our test work, we noted that the Project established a separate federally insured depository account to serve as the replacement reserve account to aid in funding extraordinary maintenance and repair and replacement of capital items, however, the depository account was not in an interest-bearing account. Questioned Costs: None Context: See ?Condition? above. Effect: All earnings including interest on the reserve must be added to the reserve. The effect of not maintaining the replacement reserve funds in an interest-bearing account resulted in missed interest earnings on these funds during the year. Cause: The Project changed financial institutions during the year and the requirement to maintain these funds in an interest-bearing account was overlooked. Recommendation: We recommend that the Project transfer its replacement reserve to a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the find. See Corrective Action Plan.
Criteria: Based on principles and guidance contained within the 2013 Internal Control?Integrated Framework as published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), management is responsible for the design, implementation and maintenance of internal controls over financial reporting with the objective that the financial statements are accurate under U.S. GAAP. As it relates to Assistance Listing Number 14.157 Supportive Housing for the Elderly (Section 202) Uniform Guidance requires that the owner is responsible for annually reexamining incomes of households occupying assisted units and making appropriate adjustments to the tenant payment and the project rental assistance payment in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 891.410(g)- Reexamination of household family income and composition - (1) Regular reexaminations. The Owner must reexamine the income and composition of the household at least every 12 months. Upon verification of the information, the Owner must make appropriate adjustments in the total tenant payment and must determine whether the household's unit size is still appropriate. The Owner must adjust tenant payment and the project rental assistance payment, and must carry out any unit transfer in accordance with HUD standards. As it relates to Assistance Listing Number 14.195 Section 8 Housing Assistance Payments Program Uniform Guidance requires that the Project reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment, as necessary in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 880.603(c)- Reexamination of family income and composition - (1) Regular reexaminations. The owner must reexamine the income and composition of all families at least every 12 months. After consultation with the family and upon verification of the information, the owner must make appropriate adjustments in the Total Tenant Payment in accordance with part 5 of this title and determine whether the family's unit size is still appropriate. The owner must adjust Tenant Rent and the Housing Assistance Payment to reflect any change in Total Tenant Payment and must carry out any unit transfer required by HUD. Condition: During our review of eligibility testing support, we noted that for the tenant?s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner?s Certification and Application for Housing Assistance Payments (HAP) for eight months of fiscal year 2022. Upon the Project?s analysis, it was determined that the total amount of the error, net of vacancies, was $37,585. Context: It was noted that the Project collected more money each month from HUD as a result of incorrectly including the utility allowance as part of the contract rent for eight months of fiscal year 2022. Effect: Incorrect rates were utilized to calculate the project tenant rental assistance payments. These incorrect rates were paid by HUD to the Project resulting in an overpayment of funds in the amount of $37,585. Cause: The Project relies heavily on a few key individuals to perform review of the tenant certifications and re-examinations. While this process of review did occur, the incorrect rents approved went undetected during the Project?s internal review process. Recommendation: We recommend that the Project establish procedures to ensure that there is a better process to check the amounts of contract rent being approved on the reexaminations and certifications of tenants. Additionally, we recommend that the monthly HAP forms are more closely reviewed by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan
Other Matter Compliance Criteria: Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 A). All disbursements from the reserve must be approved by HUD (24 CFR sections 891.405 and 891.605). Condition: During our test work, we noted that the Project established a separate federally insured depository account to serve as the replacement reserve account to aid in funding extraordinary maintenance and repair and replacement of capital items, however, the depository account was not in an interest-bearing account. Questioned Costs: None Context: See ?Condition? above. Effect: All earnings including interest on the reserve must be added to the reserve. The effect of not maintaining the replacement reserve funds in an interest-bearing account resulted in missed interest earnings on these funds during the year. Cause: The Project changed financial institutions during the year and the requirement to maintain these funds in an interest-bearing account was overlooked. Recommendation: We recommend that the Project transfer its replacement reserve to a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the find. See Corrective Action Plan.
Criteria: Based on principles and guidance contained within the 2013 Internal Control?Integrated Framework as published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), management is responsible for the design, implementation and maintenance of internal controls over financial reporting with the objective that the financial statements are accurate under U.S. GAAP. As it relates to Assistance Listing Number 14.157 Supportive Housing for the Elderly (Section 202) Uniform Guidance requires that the owner is responsible for annually reexamining incomes of households occupying assisted units and making appropriate adjustments to the tenant payment and the project rental assistance payment in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 891.410(g)- Reexamination of household family income and composition - (1) Regular reexaminations. The Owner must reexamine the income and composition of the household at least every 12 months. Upon verification of the information, the Owner must make appropriate adjustments in the total tenant payment and must determine whether the household's unit size is still appropriate. The Owner must adjust tenant payment and the project rental assistance payment, and must carry out any unit transfer in accordance with HUD standards. As it relates to Assistance Listing Number 14.195 Section 8 Housing Assistance Payments Program Uniform Guidance requires that the Project reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment, as necessary in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 880.603(c)- Reexamination of family income and composition - (1) Regular reexaminations. The owner must reexamine the income and composition of all families at least every 12 months. After consultation with the family and upon verification of the information, the owner must make appropriate adjustments in the Total Tenant Payment in accordance with part 5 of this title and determine whether the family's unit size is still appropriate. The owner must adjust Tenant Rent and the Housing Assistance Payment to reflect any change in Total Tenant Payment and must carry out any unit transfer required by HUD. Condition: During our review of eligibility testing support, we noted that for the tenant?s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner?s Certification and Application for Housing Assistance Payments (HAP) for eight months of fiscal year 2022. Upon the Project?s analysis, it was determined that the total amount of the error, net of vacancies, was $37,585. Context: It was noted that the Project collected more money each month from HUD as a result of incorrectly including the utility allowance as part of the contract rent for eight months of fiscal year 2022. Effect: Incorrect rates were utilized to calculate the project tenant rental assistance payments. These incorrect rates were paid by HUD to the Project resulting in an overpayment of funds in the amount of $37,585. Cause: The Project relies heavily on a few key individuals to perform review of the tenant certifications and re-examinations. While this process of review did occur, the incorrect rents approved went undetected during the Project?s internal review process. Recommendation: We recommend that the Project establish procedures to ensure that there is a better process to check the amounts of contract rent being approved on the reexaminations and certifications of tenants. Additionally, we recommend that the monthly HAP forms are more closely reviewed by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan
Other Matter Compliance Criteria: Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 A). All disbursements from the reserve must be approved by HUD (24 CFR sections 891.405 and 891.605). Condition: During our test work, we noted that the Project established a separate federally insured depository account to serve as the replacement reserve account to aid in funding extraordinary maintenance and repair and replacement of capital items, however, the depository account was not in an interest-bearing account. Questioned Costs: None Context: See ?Condition? above. Effect: All earnings including interest on the reserve must be added to the reserve. The effect of not maintaining the replacement reserve funds in an interest-bearing account resulted in missed interest earnings on these funds during the year. Cause: The Project changed financial institutions during the year and the requirement to maintain these funds in an interest-bearing account was overlooked. Recommendation: We recommend that the Project transfer its replacement reserve to a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the find. See Corrective Action Plan.
Criteria: Based on principles and guidance contained within the 2013 Internal Control?Integrated Framework as published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), management is responsible for the design, implementation and maintenance of internal controls over financial reporting with the objective that the financial statements are accurate under U.S. GAAP. As it relates to Assistance Listing Number 14.157 Supportive Housing for the Elderly (Section 202) Uniform Guidance requires that the owner is responsible for annually reexamining incomes of households occupying assisted units and making appropriate adjustments to the tenant payment and the project rental assistance payment in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 891.410(g)- Reexamination of household family income and composition - (1) Regular reexaminations. The Owner must reexamine the income and composition of the household at least every 12 months. Upon verification of the information, the Owner must make appropriate adjustments in the total tenant payment and must determine whether the household's unit size is still appropriate. The Owner must adjust tenant payment and the project rental assistance payment, and must carry out any unit transfer in accordance with HUD standards. As it relates to Assistance Listing Number 14.195 Section 8 Housing Assistance Payments Program Uniform Guidance requires that the Project reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment, as necessary in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 880.603(c)- Reexamination of family income and composition - (1) Regular reexaminations. The owner must reexamine the income and composition of all families at least every 12 months. After consultation with the family and upon verification of the information, the owner must make appropriate adjustments in the Total Tenant Payment in accordance with part 5 of this title and determine whether the family's unit size is still appropriate. The owner must adjust Tenant Rent and the Housing Assistance Payment to reflect any change in Total Tenant Payment and must carry out any unit transfer required by HUD. Condition: During our review of eligibility testing support, we noted that for the tenant?s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner?s Certification and Application for Housing Assistance Payments (HAP) for eight months of fiscal year 2022. Upon the Project?s analysis, it was determined that the total amount of the error, net of vacancies, was $37,585. Context: It was noted that the Project collected more money each month from HUD as a result of incorrectly including the utility allowance as part of the contract rent for eight months of fiscal year 2022. Effect: Incorrect rates were utilized to calculate the project tenant rental assistance payments. These incorrect rates were paid by HUD to the Project resulting in an overpayment of funds in the amount of $37,585. Cause: The Project relies heavily on a few key individuals to perform review of the tenant certifications and re-examinations. While this process of review did occur, the incorrect rents approved went undetected during the Project?s internal review process. Recommendation: We recommend that the Project establish procedures to ensure that there is a better process to check the amounts of contract rent being approved on the reexaminations and certifications of tenants. Additionally, we recommend that the monthly HAP forms are more closely reviewed by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan
Other Matter Compliance Criteria: Owners shall establish and maintain a replacement reserve to aid in funding extraordinary maintenance and repair and replacement of capital items. The replacement reserve funds must be deposited in a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. An amount as required by HUD will be deposited monthly in the reserve fund (Regulatory Agreement, item 5 A). All disbursements from the reserve must be approved by HUD (24 CFR sections 891.405 and 891.605). Condition: During our test work, we noted that the Project established a separate federally insured depository account to serve as the replacement reserve account to aid in funding extraordinary maintenance and repair and replacement of capital items, however, the depository account was not in an interest-bearing account. Questioned Costs: None Context: See ?Condition? above. Effect: All earnings including interest on the reserve must be added to the reserve. The effect of not maintaining the replacement reserve funds in an interest-bearing account resulted in missed interest earnings on these funds during the year. Cause: The Project changed financial institutions during the year and the requirement to maintain these funds in an interest-bearing account was overlooked. Recommendation: We recommend that the Project transfer its replacement reserve to a federally insured depository in an interest-bearing account. All earnings including interest on the reserve must be added to the reserve. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the find. See Corrective Action Plan.