Finding Reference Number: 2023-003
Title and Assistance Listing Number of Federal Program: 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding
Finding Resolution Status: In Process
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
TheCommittee of Sponsoring Organizations of the Treadway Commission (COSO) framework is a widely recognized framework for designing, implementing, and evaluating internal control systems. The COSO framework defines internal control as a process that is designed to provide reasonable security with respect to achievement of objectives of compliance with applicable laws and regulations. The COSO framework offers useful guiding principles that can be applied in establishing and operating an effective regulatory compliance program with the goal of closing compliance gaps, and ensuring the prevention of material noncompliance. The monitoring component of the COSO framework involves periodic or ongoing evaluations to verify that each of the five components internal control, including the controls that affect the principles within each component, are present and functioning. Monitoring helps ensure that internal controls continue to operate effectively.
Statement of Condition:
Management had developed activity level controls over compliance that included compliance review of all tenant certifications of income used in determining the amount of rent amounts due from eligible PRAC 811 participants (tenants) by the Coast compliance department. However, during our testing, management had no documentation evidencing such reviews had occurred; further, during our interview process of site staff (community managers), staff asserted that no such reviews had occurred, and that no feedback on tenant certifications was provided by the compliance department.
Cause:
Management had properly designed activity level controls over compliance, but those controls were not placed in operation. Proper monitoring of the compliance department was not occurring to detect the lack of proper oversight by the compliance department.
Effect or Potential Effect:
It is reasonably possible that ineligible tenants could improperly be granted tenancy to the property and given rental assistance for which they are not eligible. Such improper payments could be material.
Auditor Non-Compliance Code: S – Internal Control Deficiencies
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that controls that are properly designed are in fact placed in operation and functioning as intended. The compliance manager responsible for implementing the controls over compliance has been terminated, and senior management will institute monitoring procedures to ensure that controls over compliance are both properly designed and functioning as intended.
Context:
For the eleven files tested, no evidence existed in the files to corroborate that tenant certifications were being reviewed and approved by the compliance department.
Recommendation:
Management should have a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Finding Reference Number: 2023-003
Title and Assistance Listing Number of Federal Program: 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding
Finding Resolution Status: In Process
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
TheCommittee of Sponsoring Organizations of the Treadway Commission (COSO) framework is a widely recognized framework for designing, implementing, and evaluating internal control systems. The COSO framework defines internal control as a process that is designed to provide reasonable security with respect to achievement of objectives of compliance with applicable laws and regulations. The COSO framework offers useful guiding principles that can be applied in establishing and operating an effective regulatory compliance program with the goal of closing compliance gaps, and ensuring the prevention of material noncompliance. The monitoring component of the COSO framework involves periodic or ongoing evaluations to verify that each of the five components internal control, including the controls that affect the principles within each component, are present and functioning. Monitoring helps ensure that internal controls continue to operate effectively.
Statement of Condition:
Management had developed activity level controls over compliance that included compliance review of all tenant certifications of income used in determining the amount of rent amounts due from eligible PRAC 811 participants (tenants) by the Coast compliance department. However, during our testing, management had no documentation evidencing such reviews had occurred; further, during our interview process of site staff (community managers), staff asserted that no such reviews had occurred, and that no feedback on tenant certifications was provided by the compliance department.
Cause:
Management had properly designed activity level controls over compliance, but those controls were not placed in operation. Proper monitoring of the compliance department was not occurring to detect the lack of proper oversight by the compliance department.
Effect or Potential Effect:
It is reasonably possible that ineligible tenants could improperly be granted tenancy to the property and given rental assistance for which they are not eligible. Such improper payments could be material.
Auditor Non-Compliance Code: S – Internal Control Deficiencies
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that controls that are properly designed are in fact placed in operation and functioning as intended. The compliance manager responsible for implementing the controls over compliance has been terminated, and senior management will institute monitoring procedures to ensure that controls over compliance are both properly designed and functioning as intended.
Context:
For the eleven files tested, no evidence existed in the files to corroborate that tenant certifications were being reviewed and approved by the compliance department.
Recommendation:
Management should have a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Finding Reference Number: 2023-004
Title and Assistance Listing Number of Federal Program: 14.239 HOME Investment Partnerships
Finding Resolution Status: IN PROCESS
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: N/A NONE.
Criteria:
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Statement of Condition:
Audit procedures performed in connection with the compliance requirements associated with the HOME Investment Partnerships program revealed that bi- annual on-site inspections had not been performed.
Cause:
Due to improper oversight over compliance and turnover of site level staff the inspections were not completed as required.
Effect or Potential Effect:
Management is not in compliance with respect to the inspection requirements of the HOME Investment Partnerships program.
Auditor Non-Compliance Code: Z - Other
Questioned Costs: $0
FHA/Contract Number: 127-HD025 S3800-040: Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
Context:
We tested 6 units for compliance with the inspection requirements and 6 out of 6 files lacked documentation of inspection reports. When we broadened out our request for inspections, it was revealed that unit inspections had not occurred as required under the program requirements; however, the Corporation received a passing grade from HUD REAC as a result of its last physical inspection.
Effect: The Corporation was not in compliance with HUD requirements with respects to the housing quality and inspection requirements.
Recommendation: Management should design policies and procedures to ensure that compliance requirements over housing quality and bi-annual unit inspections are met.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non- compliance.
Response Indicator: Agree (A)
Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor and plans to take corrective actions to ensure that unit inspections of every unit is performed on at least a bi-annual basis in accordance with HUD regulations.
Finding Reference Number: 2023-004
Title and Assistance Listing Number of Federal Program: 14.239 HOME Investment Partnerships
Finding Resolution Status: IN PROCESS
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: N/A NONE.
Criteria:
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Statement of Condition:
Audit procedures performed in connection with the compliance requirements associated with the HOME Investment Partnerships program revealed that bi- annual on-site inspections had not been performed.
Cause:
Due to improper oversight over compliance and turnover of site level staff the inspections were not completed as required.
Effect or Potential Effect:
Management is not in compliance with respect to the inspection requirements of the HOME Investment Partnerships program.
Auditor Non-Compliance Code: Z - Other
Questioned Costs: $0
FHA/Contract Number: 127-HD025 S3800-040: Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
Context:
We tested 6 units for compliance with the inspection requirements and 6 out of 6 files lacked documentation of inspection reports. When we broadened out our request for inspections, it was revealed that unit inspections had not occurred as required under the program requirements; however, the Corporation received a passing grade from HUD REAC as a result of its last physical inspection.
Effect: The Corporation was not in compliance with HUD requirements with respects to the housing quality and inspection requirements.
Recommendation: Management should design policies and procedures to ensure that compliance requirements over housing quality and bi-annual unit inspections are met.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non- compliance.
Response Indicator: Agree (A)
Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor and plans to take corrective actions to ensure that unit inspections of every unit is performed on at least a bi-annual basis in accordance with HUD regulations.
Finding Reference Number: 2023-004
Title and Assistance Listing Number of Federal Program: 14.239 HOME Investment Partnerships
Finding Resolution Status: IN PROCESS
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: N/A NONE.
Criteria:
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Statement of Condition:
Audit procedures performed in connection with the compliance requirements associated with the HOME Investment Partnerships program revealed that bi- annual on-site inspections had not been performed.
Cause:
Due to improper oversight over compliance and turnover of site level staff the inspections were not completed as required.
Effect or Potential Effect:
Management is not in compliance with respect to the inspection requirements of the HOME Investment Partnerships program.
Auditor Non-Compliance Code: Z - Other
Questioned Costs: $0
FHA/Contract Number: 127-HD025 S3800-040: Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
Context:
We tested 6 units for compliance with the inspection requirements and 6 out of 6 files lacked documentation of inspection reports. When we broadened out our request for inspections, it was revealed that unit inspections had not occurred as required under the program requirements; however, the Corporation received a passing grade from HUD REAC as a result of its last physical inspection.
Effect: The Corporation was not in compliance with HUD requirements with respects to the housing quality and inspection requirements.
Recommendation: Management should design policies and procedures to ensure that compliance requirements over housing quality and bi-annual unit inspections are met.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non- compliance.
Response Indicator: Agree (A)
Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor and plans to take corrective actions to ensure that unit inspections of every unit is performed on at least a bi-annual basis in accordance with HUD regulations.
Finding Reference Number: 2023-005
Title and Assistance Listing Number of Federal Program: CFDA 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding: Federal Award Finding Finding Resolution Status: In Progress
Information on Universe Population Size: Not Applicable Sample Size Information: Not Applicable
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
HUD regulatory agreement requires residual receipts to be deposited in a segregated account within 90 days following year end.
Statement of Condition:
The management company made the required deposit to residual receipts however the deposit was made after the required due date.
Cause:
Discussion with the auditor about surplus cash occurred on September 23, 2022, but due to management oversight, the deposit was not made until October 11, 2022.
Auditor Non-Compliance Code: B - Failure to make required residual receipts deposit
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, management inadvertently neglected to make the deposit timely.
FHA/Contract Number: 127-HD025 Questioned Costs: $0
Context:
The deposit to the residual receipts account was made on October 11, 2022, after the required due date.
Effect:
The Corporation was not in compliance with HUD requirements with respects to the timing of the residual receipts deposit.
Recommendation:
Management should ensure that the required residual receipts deposit is made by the required due date.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non-compliance.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that future residual receipts deposits are made timely.
Finding Reference Number: 2023-005
Title and Assistance Listing Number of Federal Program: CFDA 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding: Federal Award Finding Finding Resolution Status: In Progress
Information on Universe Population Size: Not Applicable Sample Size Information: Not Applicable
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
HUD regulatory agreement requires residual receipts to be deposited in a segregated account within 90 days following year end.
Statement of Condition:
The management company made the required deposit to residual receipts however the deposit was made after the required due date.
Cause:
Discussion with the auditor about surplus cash occurred on September 23, 2022, but due to management oversight, the deposit was not made until October 11, 2022.
Auditor Non-Compliance Code: B - Failure to make required residual receipts deposit
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, management inadvertently neglected to make the deposit timely.
FHA/Contract Number: 127-HD025 Questioned Costs: $0
Context:
The deposit to the residual receipts account was made on October 11, 2022, after the required due date.
Effect:
The Corporation was not in compliance with HUD requirements with respects to the timing of the residual receipts deposit.
Recommendation:
Management should ensure that the required residual receipts deposit is made by the required due date.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non-compliance.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that future residual receipts deposits are made timely.
Finding Reference Number: 2023-003
Title and Assistance Listing Number of Federal Program: 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding
Finding Resolution Status: In Process
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
TheCommittee of Sponsoring Organizations of the Treadway Commission (COSO) framework is a widely recognized framework for designing, implementing, and evaluating internal control systems. The COSO framework defines internal control as a process that is designed to provide reasonable security with respect to achievement of objectives of compliance with applicable laws and regulations. The COSO framework offers useful guiding principles that can be applied in establishing and operating an effective regulatory compliance program with the goal of closing compliance gaps, and ensuring the prevention of material noncompliance. The monitoring component of the COSO framework involves periodic or ongoing evaluations to verify that each of the five components internal control, including the controls that affect the principles within each component, are present and functioning. Monitoring helps ensure that internal controls continue to operate effectively.
Statement of Condition:
Management had developed activity level controls over compliance that included compliance review of all tenant certifications of income used in determining the amount of rent amounts due from eligible PRAC 811 participants (tenants) by the Coast compliance department. However, during our testing, management had no documentation evidencing such reviews had occurred; further, during our interview process of site staff (community managers), staff asserted that no such reviews had occurred, and that no feedback on tenant certifications was provided by the compliance department.
Cause:
Management had properly designed activity level controls over compliance, but those controls were not placed in operation. Proper monitoring of the compliance department was not occurring to detect the lack of proper oversight by the compliance department.
Effect or Potential Effect:
It is reasonably possible that ineligible tenants could improperly be granted tenancy to the property and given rental assistance for which they are not eligible. Such improper payments could be material.
Auditor Non-Compliance Code: S – Internal Control Deficiencies
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that controls that are properly designed are in fact placed in operation and functioning as intended. The compliance manager responsible for implementing the controls over compliance has been terminated, and senior management will institute monitoring procedures to ensure that controls over compliance are both properly designed and functioning as intended.
Context:
For the eleven files tested, no evidence existed in the files to corroborate that tenant certifications were being reviewed and approved by the compliance department.
Recommendation:
Management should have a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Finding Reference Number: 2023-003
Title and Assistance Listing Number of Federal Program: 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding
Finding Resolution Status: In Process
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
TheCommittee of Sponsoring Organizations of the Treadway Commission (COSO) framework is a widely recognized framework for designing, implementing, and evaluating internal control systems. The COSO framework defines internal control as a process that is designed to provide reasonable security with respect to achievement of objectives of compliance with applicable laws and regulations. The COSO framework offers useful guiding principles that can be applied in establishing and operating an effective regulatory compliance program with the goal of closing compliance gaps, and ensuring the prevention of material noncompliance. The monitoring component of the COSO framework involves periodic or ongoing evaluations to verify that each of the five components internal control, including the controls that affect the principles within each component, are present and functioning. Monitoring helps ensure that internal controls continue to operate effectively.
Statement of Condition:
Management had developed activity level controls over compliance that included compliance review of all tenant certifications of income used in determining the amount of rent amounts due from eligible PRAC 811 participants (tenants) by the Coast compliance department. However, during our testing, management had no documentation evidencing such reviews had occurred; further, during our interview process of site staff (community managers), staff asserted that no such reviews had occurred, and that no feedback on tenant certifications was provided by the compliance department.
Cause:
Management had properly designed activity level controls over compliance, but those controls were not placed in operation. Proper monitoring of the compliance department was not occurring to detect the lack of proper oversight by the compliance department.
Effect or Potential Effect:
It is reasonably possible that ineligible tenants could improperly be granted tenancy to the property and given rental assistance for which they are not eligible. Such improper payments could be material.
Auditor Non-Compliance Code: S – Internal Control Deficiencies
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that controls that are properly designed are in fact placed in operation and functioning as intended. The compliance manager responsible for implementing the controls over compliance has been terminated, and senior management will institute monitoring procedures to ensure that controls over compliance are both properly designed and functioning as intended.
Context:
For the eleven files tested, no evidence existed in the files to corroborate that tenant certifications were being reviewed and approved by the compliance department.
Recommendation:
Management should have a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Finding Reference Number: 2023-004
Title and Assistance Listing Number of Federal Program: 14.239 HOME Investment Partnerships
Finding Resolution Status: IN PROCESS
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: N/A NONE.
Criteria:
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Statement of Condition:
Audit procedures performed in connection with the compliance requirements associated with the HOME Investment Partnerships program revealed that bi- annual on-site inspections had not been performed.
Cause:
Due to improper oversight over compliance and turnover of site level staff the inspections were not completed as required.
Effect or Potential Effect:
Management is not in compliance with respect to the inspection requirements of the HOME Investment Partnerships program.
Auditor Non-Compliance Code: Z - Other
Questioned Costs: $0
FHA/Contract Number: 127-HD025 S3800-040: Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
Context:
We tested 6 units for compliance with the inspection requirements and 6 out of 6 files lacked documentation of inspection reports. When we broadened out our request for inspections, it was revealed that unit inspections had not occurred as required under the program requirements; however, the Corporation received a passing grade from HUD REAC as a result of its last physical inspection.
Effect: The Corporation was not in compliance with HUD requirements with respects to the housing quality and inspection requirements.
Recommendation: Management should design policies and procedures to ensure that compliance requirements over housing quality and bi-annual unit inspections are met.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non- compliance.
Response Indicator: Agree (A)
Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor and plans to take corrective actions to ensure that unit inspections of every unit is performed on at least a bi-annual basis in accordance with HUD regulations.
Finding Reference Number: 2023-004
Title and Assistance Listing Number of Federal Program: 14.239 HOME Investment Partnerships
Finding Resolution Status: IN PROCESS
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: N/A NONE.
Criteria:
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Statement of Condition:
Audit procedures performed in connection with the compliance requirements associated with the HOME Investment Partnerships program revealed that bi- annual on-site inspections had not been performed.
Cause:
Due to improper oversight over compliance and turnover of site level staff the inspections were not completed as required.
Effect or Potential Effect:
Management is not in compliance with respect to the inspection requirements of the HOME Investment Partnerships program.
Auditor Non-Compliance Code: Z - Other
Questioned Costs: $0
FHA/Contract Number: 127-HD025 S3800-040: Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
Context:
We tested 6 units for compliance with the inspection requirements and 6 out of 6 files lacked documentation of inspection reports. When we broadened out our request for inspections, it was revealed that unit inspections had not occurred as required under the program requirements; however, the Corporation received a passing grade from HUD REAC as a result of its last physical inspection.
Effect: The Corporation was not in compliance with HUD requirements with respects to the housing quality and inspection requirements.
Recommendation: Management should design policies and procedures to ensure that compliance requirements over housing quality and bi-annual unit inspections are met.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non- compliance.
Response Indicator: Agree (A)
Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor and plans to take corrective actions to ensure that unit inspections of every unit is performed on at least a bi-annual basis in accordance with HUD regulations.
Finding Reference Number: 2023-004
Title and Assistance Listing Number of Federal Program: 14.239 HOME Investment Partnerships
Finding Resolution Status: IN PROCESS
Information on Universe Population Size: 17 rental units
Sample Size Information: 6 rental units
Identification of Repeat Finding and Finding Reference Number: N/A NONE.
Criteria:
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Statement of Condition:
Audit procedures performed in connection with the compliance requirements associated with the HOME Investment Partnerships program revealed that bi- annual on-site inspections had not been performed.
Cause:
Due to improper oversight over compliance and turnover of site level staff the inspections were not completed as required.
Effect or Potential Effect:
Management is not in compliance with respect to the inspection requirements of the HOME Investment Partnerships program.
Auditor Non-Compliance Code: Z - Other
Questioned Costs: $0
FHA/Contract Number: 127-HD025 S3800-040: Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
Context:
We tested 6 units for compliance with the inspection requirements and 6 out of 6 files lacked documentation of inspection reports. When we broadened out our request for inspections, it was revealed that unit inspections had not occurred as required under the program requirements; however, the Corporation received a passing grade from HUD REAC as a result of its last physical inspection.
Effect: The Corporation was not in compliance with HUD requirements with respects to the housing quality and inspection requirements.
Recommendation: Management should design policies and procedures to ensure that compliance requirements over housing quality and bi-annual unit inspections are met.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations: Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non- compliance.
Response Indicator: Agree (A)
Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor and plans to take corrective actions to ensure that unit inspections of every unit is performed on at least a bi-annual basis in accordance with HUD regulations.
Finding Reference Number: 2023-005
Title and Assistance Listing Number of Federal Program: CFDA 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding: Federal Award Finding Finding Resolution Status: In Progress
Information on Universe Population Size: Not Applicable Sample Size Information: Not Applicable
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
HUD regulatory agreement requires residual receipts to be deposited in a segregated account within 90 days following year end.
Statement of Condition:
The management company made the required deposit to residual receipts however the deposit was made after the required due date.
Cause:
Discussion with the auditor about surplus cash occurred on September 23, 2022, but due to management oversight, the deposit was not made until October 11, 2022.
Auditor Non-Compliance Code: B - Failure to make required residual receipts deposit
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, management inadvertently neglected to make the deposit timely.
FHA/Contract Number: 127-HD025 Questioned Costs: $0
Context:
The deposit to the residual receipts account was made on October 11, 2022, after the required due date.
Effect:
The Corporation was not in compliance with HUD requirements with respects to the timing of the residual receipts deposit.
Recommendation:
Management should ensure that the required residual receipts deposit is made by the required due date.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non-compliance.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that future residual receipts deposits are made timely.
Finding Reference Number: 2023-005
Title and Assistance Listing Number of Federal Program: CFDA 14.181 Supportive Housing for Persons with Disabilities
Type of Finding: Federal Award Finding: Federal Award Finding Finding Resolution Status: In Progress
Information on Universe Population Size: Not Applicable Sample Size Information: Not Applicable
Identification of Repeat Finding and Finding Reference Number: Not Applicable.
Criteria:
HUD regulatory agreement requires residual receipts to be deposited in a segregated account within 90 days following year end.
Statement of Condition:
The management company made the required deposit to residual receipts however the deposit was made after the required due date.
Cause:
Discussion with the auditor about surplus cash occurred on September 23, 2022, but due to management oversight, the deposit was not made until October 11, 2022.
Auditor Non-Compliance Code: B - Failure to make required residual receipts deposit
Questioned Costs: $0
Reporting Views of Responsible Officials:
After discussion with the auditor, management inadvertently neglected to make the deposit timely.
FHA/Contract Number: 127-HD025 Questioned Costs: $0
Context:
The deposit to the residual receipts account was made on October 11, 2022, after the required due date.
Effect:
The Corporation was not in compliance with HUD requirements with respects to the timing of the residual receipts deposit.
Recommendation:
Management should ensure that the required residual receipts deposit is made by the required due date.
Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations:
Management agrees with the finding and the auditor’s recommendation, and will take the necessary steps to mitigate further non-compliance.
Response Indicator: Agree (A) Completion Date: November 27, 2023
Response:
Management agrees with the recommendation of the auditor, and will ensure that future residual receipts deposits are made timely.