FINDING NO. 2022-001: INEFFECTIVE OVERSIGHT AND OPERATION OF INTERNAL CONTROLS OVER COMPLIANCE BY MANAGEMENT Volunteer Homes for Elderly, Inc. had a Management Review (MOR) during the period under audit. The MOR had a significant number of findings in the Leasing and Occupancy section. The findings were related to the following: missing HUD required information on tenant selection plan, house rules, Violence Against Women Act (VAWA) emergency plan, eviction and rejection notices, tenant applications, marketing materials, HUD Forms, and EIV policies and procedures; EIV requirements not executed as required; new hire detail reports not filed correctly; tenant files missing HUD required documents; tenant file documents missing signatures and dates from required parties; incorrect information listed on HUD Form 9887/A; incorrect or miscalculated income, assets, and medical expenses used on HUD Form 50059; and tenants charged estimates for damages at move-out instead of actual costs. CRITERIA: HUD compliance requirements can be found in the HUD Handbook 4350.3 and VAWA requirements can be found at 24 CFR 5.2005 and FR-5720-F-03. CAUSE OF CONDITION: Management agent and managers not aware of requirements, not following procedures properly, does not have proper procedures in place, oversight, and error. RECOMMENDATION: Through compliance testing audit procedures, auditor reviewed the corrective action plan, corrections, and correspondence regarding the MOR findings and therefore, validated the actions taken. In addition, auditor recommends management agent put additional procedures in place to periodically review HUD Handbook 4350.3, periodically review property documents to ensure they are up to date with HUD requirements, and ensure managers know and are complying with HUD requirements.
FINDING NO. 2022-002: INEFFECTIVE OVERSIGHT AND OPERATION OF INTERNAL CONTROLS OVER COMPLIANCE BY MANAGEMENT Volunteer Homes for Elderly, Inc.?s managers are not keeping EIV data as required by HUD. After being informed by the management agent to destroy EIV data that is greater than three years after tenancy, managers proceeded to destroy EIV data before the retention period expired. CRITERIA: According to HUD Handbook 4350.3, owners must retain EIV data in the tenant file for the term of tenancy plus three years. Once retention period expires, owners must dispose of EIV data in proper manner. The requirements of EIV are included in chapter 9 of the HUD handbook. CAUSE OF CONDITION: The managers are not following requirements for EIV data pursuant to the HUD Handbook 4350.3. RECOMMENDATION: Auditor recommends management agent provide additional training to managers regarding retention period of EIV data and put proper controls in place to ensure the managers are complying with HUD requirements.
FINDING NO. 2022-003: INEFFECTIVE OVERSIGHT AND OPERATION OF INTERNAL CONTROLS OVER COMPLIANCE BY MANAGEMENT Volunteer Homes for Elderly, Inc.?s managers did not follow all HUD requirements when going through the tenant recertification process. The tenant files tested for internal controls over compliance contained multiple deficiencies including missing copy of social security card in order to verify social security number; missing income verification; missing Ethnic and Racial Data conformation; incorrect calculation of tenant assets; incorrect income used on HUD Form 50059, and missing tenant signature and date on Resident Rights and Responsibilities acknowledgment. CRITERIA: According to the HUD Handbook 4350.3: 1. All applicant and tenant household members must disclose and provide verification of the complete and accurate social security number assigned to them except for those individuals who do not contend eligible immigration status. 2. Owners must include verification documentation in the tenant file. 3. Owners must gather data about the race and ethnicity of applicants and tenants so that HUD can easily spot possible discrimination, track racial or ethnic concentrations, and focus enforcement actions on owners with racially or ethnically identifiable properties. 4. Owners must verify all income assets, expenses, deductions, family characteristics, and circumstances that affect family eligibility or level of assistance: for savings accounts, use the current balance and for checking accounts, use the average balance for the last six months. 5. Annual income is defined as all amounts anticipated to be received from a source outside the family during the 12-month period following admission or annual recertification and owner calculates projected annual income by annualizing current income. 6. Owners must provide applicants and tenants with a copy of the Resident Rights and Responsibilities brochure at move-in and annual recertification and all family members at least 18 years of age must acknowledge receipt of brochure by signing and dating the acknowledgement. CAUSE OF CONDITION: The management agent did not have systems in place to ensure managers know of and are complying with all HUD requirements pursuant to the HUD Handbook 4350.3. RECOMMENDATION: Auditor recommends management review HUD Handbook 4350.3 and put proper procedures in place to ensure managers know of applicable HUD requirements and are complying with HUD requirements.
FINDING NO. 2022-001: INEFFECTIVE OVERSIGHT AND OPERATION OF INTERNAL CONTROLS OVER COMPLIANCE BY MANAGEMENT Volunteer Homes for Elderly, Inc. had a Management Review (MOR) during the period under audit. The MOR had a significant number of findings in the Leasing and Occupancy section. The findings were related to the following: missing HUD required information on tenant selection plan, house rules, Violence Against Women Act (VAWA) emergency plan, eviction and rejection notices, tenant applications, marketing materials, HUD Forms, and EIV policies and procedures; EIV requirements not executed as required; new hire detail reports not filed correctly; tenant files missing HUD required documents; tenant file documents missing signatures and dates from required parties; incorrect information listed on HUD Form 9887/A; incorrect or miscalculated income, assets, and medical expenses used on HUD Form 50059; and tenants charged estimates for damages at move-out instead of actual costs. CRITERIA: HUD compliance requirements can be found in the HUD Handbook 4350.3 and VAWA requirements can be found at 24 CFR 5.2005 and FR-5720-F-03. CAUSE OF CONDITION: Management agent and managers not aware of requirements, not following procedures properly, does not have proper procedures in place, oversight, and error. RECOMMENDATION: Through compliance testing audit procedures, auditor reviewed the corrective action plan, corrections, and correspondence regarding the MOR findings and therefore, validated the actions taken. In addition, auditor recommends management agent put additional procedures in place to periodically review HUD Handbook 4350.3, periodically review property documents to ensure they are up to date with HUD requirements, and ensure managers know and are complying with HUD requirements.
FINDING NO. 2022-002: INEFFECTIVE OVERSIGHT AND OPERATION OF INTERNAL CONTROLS OVER COMPLIANCE BY MANAGEMENT Volunteer Homes for Elderly, Inc.?s managers are not keeping EIV data as required by HUD. After being informed by the management agent to destroy EIV data that is greater than three years after tenancy, managers proceeded to destroy EIV data before the retention period expired. CRITERIA: According to HUD Handbook 4350.3, owners must retain EIV data in the tenant file for the term of tenancy plus three years. Once retention period expires, owners must dispose of EIV data in proper manner. The requirements of EIV are included in chapter 9 of the HUD handbook. CAUSE OF CONDITION: The managers are not following requirements for EIV data pursuant to the HUD Handbook 4350.3. RECOMMENDATION: Auditor recommends management agent provide additional training to managers regarding retention period of EIV data and put proper controls in place to ensure the managers are complying with HUD requirements.
FINDING NO. 2022-003: INEFFECTIVE OVERSIGHT AND OPERATION OF INTERNAL CONTROLS OVER COMPLIANCE BY MANAGEMENT Volunteer Homes for Elderly, Inc.?s managers did not follow all HUD requirements when going through the tenant recertification process. The tenant files tested for internal controls over compliance contained multiple deficiencies including missing copy of social security card in order to verify social security number; missing income verification; missing Ethnic and Racial Data conformation; incorrect calculation of tenant assets; incorrect income used on HUD Form 50059, and missing tenant signature and date on Resident Rights and Responsibilities acknowledgment. CRITERIA: According to the HUD Handbook 4350.3: 1. All applicant and tenant household members must disclose and provide verification of the complete and accurate social security number assigned to them except for those individuals who do not contend eligible immigration status. 2. Owners must include verification documentation in the tenant file. 3. Owners must gather data about the race and ethnicity of applicants and tenants so that HUD can easily spot possible discrimination, track racial or ethnic concentrations, and focus enforcement actions on owners with racially or ethnically identifiable properties. 4. Owners must verify all income assets, expenses, deductions, family characteristics, and circumstances that affect family eligibility or level of assistance: for savings accounts, use the current balance and for checking accounts, use the average balance for the last six months. 5. Annual income is defined as all amounts anticipated to be received from a source outside the family during the 12-month period following admission or annual recertification and owner calculates projected annual income by annualizing current income. 6. Owners must provide applicants and tenants with a copy of the Resident Rights and Responsibilities brochure at move-in and annual recertification and all family members at least 18 years of age must acknowledge receipt of brochure by signing and dating the acknowledgement. CAUSE OF CONDITION: The management agent did not have systems in place to ensure managers know of and are complying with all HUD requirements pursuant to the HUD Handbook 4350.3. RECOMMENDATION: Auditor recommends management review HUD Handbook 4350.3 and put proper procedures in place to ensure managers know of applicable HUD requirements and are complying with HUD requirements.