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Finding No. 2023-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Uniform Guidance Compliance Requirement Code: E-Eligibility Criteria Each owner must comply with the requirements set forth in 24 CFR Part 92 regulations as outlined in the "Compliance in HOME Re...
Finding No. 2023-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Uniform Guidance Compliance Requirement Code: E-Eligibility Criteria Each owner must comply with the requirements set forth in 24 CFR Part 92 regulations as outlined in the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD which requires the property to maintain the contracted number of HOME units as well as the designated splits in bedroom size and High Home/Low Home unit ratios. Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. Cause Management’s policies with respect to maintaining the number and split of contracted HOME units were not consistently followed. Effect or Potential Effect The procedures for determining and maintaining the correct HOME units within the property were not applied. This could result in ineligible tenants occupying HOME designated units. Questioned Costs: Not applicable. Context In connection with the procedures applied to our HOME units testing, one of the five properties tested did not meet the contracted HOME units size portfolio (there should be four 3-bedroom units (there are 5); and there should be three 4-bedroom units (there are 2)). Repeat Finding: Yes - Finding 2022-003 Recommendation Management should follow procedures in place to ensure consistent application and adherence to the requirements in accordance with the “Compliance in HOME Rental Projects: A Guide for Property Owners” published by HUD. Views of Responsible Officials A unit will be re-classified the next time there is a vacant unit of the corresponding size/type.
Finding No. 2023-002 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Uniform Guidance Compliance Requirement Code: E-Eligibility Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Compliance in State ...
Finding No. 2023-002 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Uniform Guidance Compliance Requirement Code: E-Eligibility Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual. Condition In connection with our lease file review we noted four instances of eight tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy. Cause Management’s policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual were not consistently followed. Effect or Potential Effect This could result in units being rented to ineligible tenants. Questioned Costs: Not applicable. Context In connection with the procedures applied to our HOME units testing, four of the eight tenants tested did not have the a 3rd party income verification in accordance with policy. Repeat Finding: Yes - Finding 2022-002 Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that recertifications and correct income verification procedures are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual. Views of Responsible Officials For the properties in Washington, they have several sources of HOME funds based on the issuing jurisdiction State, County or City that adds a layer of complexity to the recertification process and due to staffing turnover, both at the properties and REACH main office some of the HOME 3rd party income verifications were missed at recertification. Management has established policies and procedures for complying with the HOME program which includes a centralized tracker for HOME certifications.
Finding No. 2023-001 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Uniform Guidance Compliance Requirement Code: N-Special Tests and Provisions Criteria During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized...
Finding No. 2023-001 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Uniform Guidance Compliance Requirement Code: N-Special Tests and Provisions 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)). Condition The owner did not ensure passing HQS inspections were performed during 2023. Cause Management did not have in place proper procedures and controls to ensure that HQS inspections were performed during the year ended December 31, 2023. Effect or Potential Effect Housing units may be out of compliance with HUD Quality Standards. Questioned Costs: Not applicable. Context In connection with the procedures applied to tenant file testing there were 8 instances of the 8 files tested where the passing HQS inspections were not performed during the year ended December 31, 2023. Repeat Finding: Yes - Finding 2022-001 Recommendation Management should resume making sure all units meet the HUD Housing Quality Standards and ensure that the responses to any findings are cleared timely. Views of Responsible Officials REACH did return to doing HQS Inspections in 2023. With staffing shortages, it is possible that not every unit was inspected in 2023. REACH continued to reestablish our annual unit inspection process post COVID in 2024. For the finding related to Addy St. This property is managed by a 3rd party management company, REACH’s Asset Management team will work with the management company to ensure all inspections are happening.
Re: Independent Audit FYE September 30, 2023—Management Response Dear Mr. Zenk: This letter serves as the Muskegon Housing Commission’s follow-up and completed response to the finding reported in the Independent Audit FYE September 30, 2023.Finding 2023-001 Section 8 Housing Choice Voucher Program T...
Re: Independent Audit FYE September 30, 2023—Management Response Dear Mr. Zenk: This letter serves as the Muskegon Housing Commission’s follow-up and completed response to the finding reported in the Independent Audit FYE September 30, 2023.Finding 2023-001 Section 8 Housing Choice Voucher Program Tenant Files were missing supporting documents and not timely recertified. Corrective Action: MHC has worked to make corrections to all files and get them in correct order. All recertifications are started 120 days prior to the date. Beginning July 1, 2024 all files will have a checklist completed and the Executive Director will sign and verify all documents are included. We will utilize the checklists attached and make any updates as needed per regulations.
Condition: The Organization could not provide one salary authorization from for sample selection of 40 employees. Corrective Action Planned: The Organization has implemented a process to ensure that all salary authorizations are properly obtained and stored. When there is any change in an employee...
Condition: The Organization could not provide one salary authorization from for sample selection of 40 employees. Corrective Action Planned: The Organization has implemented a process to ensure that all salary authorizations are properly obtained and stored. When there is any change in an employee's status or salary, an Employee Status Form is completed and signed by the employee, their supervisor, and Human Resources, and when required by the COO and CEO. Additionally, the salary authorization form is added to a secure shared file drive. The shared file drive includes a section where all salary changes are listed. Both HR and Finance initial off to confirm that each salary change is supported by the proper documentation during the payroll review process. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer. Anticipated Completion Date: Implemented.
Condition: No documentation of employee time approval by supervisors could be provided. The payroll clerk processes the payroll and finance director approves through the releasing of the payroll. However, there is no formal documentation of the overall review of the payroll process and the supervi...
Condition: No documentation of employee time approval by supervisors could be provided. The payroll clerk processes the payroll and finance director approves through the releasing of the payroll. However, there is no formal documentation of the overall review of the payroll process and the supervisors' approval to time recorded by employees. Corrective Action Planned: The Organization has implemented a new payroll process using the ADP system. Employees are now required to approve their own time within the ADP portal, and this approval is documented. Following this, supervisors review and approve their employee's time, which is also documented in the portal. Human Resources then prepares the payroll, reviewing all entries and initialing a shared file of payroll items and providing backup for changes. Once HR confirms accuracy, they notify Finance. Finance then reviews the payroll, with the Finance Manager providing the final approval within ADP once all items are confirmed. The entire process is fully documented, with approvals recorded within the ADP by employees and supervisors and the shared file drive where HR and Finance intimal off on the reviewed payroll times, ensuring a traceable record of the entire payroll approval process. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer. Anticipated Completion Date: Implemented.
Condition: The Organization did not maintain property documentation to support the review of the report prior to submission to the grantor, other than the review done by the preparer. Corrective Action Planned: The Organization has hire a new Chief Financial Officer as well as additional supporting ...
Condition: The Organization did not maintain property documentation to support the review of the report prior to submission to the grantor, other than the review done by the preparer. Corrective Action Planned: The Organization has hire a new Chief Financial Officer as well as additional supporting staff within the finance department. The accounting staff was restructured in November 2024 with the addition of a Finance Manager and Senior Accountant to strengthen internal controls and facilitate segregation of duties and best practices for day-to-day activities. In addition to review of month-end journal entries, reporting requirements with additional review as also implemented in 2025. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer. Anticipated Completion Date: Implemented.
Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hire a new Chief Financial Officer as well as additional supporting staff within the finance department. The accounting staff was restructured in ...
Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hire a new Chief Financial Officer as well as additional supporting staff within the finance department. The accounting staff was restructured in November 2024 with the addition of a Finance Manager and Senior Accountant to strengthen internal control and facilitate segregation of duties best practices for day-to-day activities. In addition to review of month-end journal entries, reporting requirements with additional review was also implemented in 2025. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer. Anticipated Completion Date: Implemented.
Condition: The Organization lacks consistently applied processes and procedures related to the application of the sliding fee scale. The Organization also lacks a clear review process related to the sliding fee scale to identify errors quickly to allow for corrections to be made in a timely manner....
Condition: The Organization lacks consistently applied processes and procedures related to the application of the sliding fee scale. The Organization also lacks a clear review process related to the sliding fee scale to identify errors quickly to allow for corrections to be made in a timely manner. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Billing and Collections Policy was updated to waive co-pays for students in the School-Based Program. The Billing Department is in the process of auditing and implementing quarterly feedback & training sessions for the Operations Department for training and compliance for the Sliding Fee Discount Program. This process was implemented in 2025. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer. Anticipated Completion Date: Implemented.
Description of Finding: A payment made for food for an event was submitted for reimbursement under the VOCA program, and VOCA specifically prohibits the use of federal funds for food and beverages for conferences. Planned Corrective Action: The organization has ceased offering the services related t...
Description of Finding: A payment made for food for an event was submitted for reimbursement under the VOCA program, and VOCA specifically prohibits the use of federal funds for food and beverages for conferences. Planned Corrective Action: The organization has ceased offering the services related to the VOCA grant. That being said, the organization will implement a policy that will prevent unallowed costs under the VOCA program or a similar program by implementing the following: 1. Policy Update: Revise the Grant Compliance Policy to include a clear list of unallowed costs under VOCA and other federal programs, with specific reference to food and beverage restrictions. 2. Pre-Approval Process: Require all VOCA-related expenses to be pre-approved by the Grant Manager, who will verify compliance with VOCA guidelines. 3. Training: Conduct training for all staff involved in VOCA program spending on allowable and unallowed costs by June 30, 2025. 4. Repayment: Reimburse the VOCA program for the unallowed food expense from nonfederal funds by June 15, 2025, and document the transaction. 5. Monitoring: The Grant Manager will perform quarterly reviews of VOCA expenditures to ensure compliance, with results reported to the Executive Director. Responsible Party: Grant Manager, overseen by Caroline Catlender, Executive Director Anticipated Completion Date: July 15, 2025
View Audit 361880 Questioned Costs: $1
Statement of Condition #2023-008: The Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending March 31, 2023. Recommendation: The annual financial statements should be issued in a timely manner pursuant to the time f...
Statement of Condition #2023-008: The Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending March 31, 2023. Recommendation: The annual financial statements should be issued in a timely manner pursuant to the time frame set forth by HUD. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. The audited financial statements have been submitted to HUD. No further action is required.
Statement of Condition #2023-005: At March 31, 2023, the Partnership's residual receipts account was not invested in an interest bearing account. Recommendation: The Agent should transfer the residual receipts account to an interest bearing account. Action(s) taken or planned on the finding: Agre...
Statement of Condition #2023-005: At March 31, 2023, the Partnership's residual receipts account was not invested in an interest bearing account. Recommendation: The Agent should transfer the residual receipts account to an interest bearing account. Action(s) taken or planned on the finding: Agreed. The Agent concurs with the finding and the auditor's recommendation. The Partnership will transfer the residual receipts account to an interest bearing account.
Statement of Condition #2023-004: During the year ended March 31, 2023, the Partnership made distributions of $40,398 in excess of surplus cash. Recommendation: Management should limit the payment of distributions to surplus cash. Action(s) taken or planned on the finding: Agreed. Management will l...
Statement of Condition #2023-004: During the year ended March 31, 2023, the Partnership made distributions of $40,398 in excess of surplus cash. Recommendation: Management should limit the payment of distributions to surplus cash. Action(s) taken or planned on the finding: Agreed. Management will limit future distributions to surplus cash.
View Audit 361711 Questioned Costs: $1
Statement of Condition #2023-007: The Form SF-SAC Single Audit Data Collection Form for the years ended March 31, 2023 and 2022 were not submitted to the federal audit clearinghouse in the required timeframe. Recommendation: The Corporation should submit the Form SF-SAC Single Audit Data Collection ...
Statement of Condition #2023-007: The Form SF-SAC Single Audit Data Collection Form for the years ended March 31, 2023 and 2022 were not submitted to the federal audit clearinghouse in the required timeframe. Recommendation: The Corporation should submit the Form SF-SAC Single Audit Data Collection Form for the years ended March 31, 2023 and 2022 as soon as practical. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. The audited financial statements have been submitted to the federal clearinghouse. No further action is required.
Statement of Condition #2023-006 The Corporation's accounting books and records as submitted for audit included certain accounts which were not presented in accordance with accounting standards generally accepted in the United States of America ("GAAP"). As a result, management was required to provi...
Statement of Condition #2023-006 The Corporation's accounting books and records as submitted for audit included certain accounts which were not presented in accordance with accounting standards generally accepted in the United States of America ("GAAP"). As a result, management was required to provide audit adjustments to present the March 31, 2023 financial statements in accordance with GAAP. Recommendation: The Agent should maintain a comprehensive set of accounting books and records in accordance with GAAP. Action(s) taken or planned on the finding: Agreed. The Agent concurs with the finding and the auditor's recommendation. The Corporation will ensure that the Agent will maintain a comprehensive set of accounting books and records in accordance with GAAP.
Statement of Condition #2023-003: For the year ended March 31, 2023, the Corporation paid $28,300 on behalf of a related entity without HUD approval. Recommendation: The related entity should repay $28,300 to the Corporation. The Agent should consider obtaining written approval from HUD prior to mak...
Statement of Condition #2023-003: For the year ended March 31, 2023, the Corporation paid $28,300 on behalf of a related entity without HUD approval. Recommendation: The related entity should repay $28,300 to the Corporation. The Agent should consider obtaining written approval from HUD prior to making any future distributions or payments to related entities. Action(s) Taken or Planned on the Finding: Agreed. The Agent concurs with the finding and agrees with the auditor's recommendation. The related entity will repay $28,300 to the Corporation.
View Audit 361711 Questioned Costs: $1
Statement of Condition #2023-002: During the year ended March 31, 2023, the Corporation did not make the required deposit to the residual receipts account within 90 days after the end of the fiscal year, resulting in the account being underfunded at year end. Recommendation: The Agent should transfe...
Statement of Condition #2023-002: During the year ended March 31, 2023, the Corporation did not make the required deposit to the residual receipts account within 90 days after the end of the fiscal year, resulting in the account being underfunded at year end. Recommendation: The Agent should transfer $51,630 from the REDI III operating account to the residual receipts account and $19,654 from the REDI IV operating account to the residual receipts account. The Agent should make all required deposits to the residual receipts account within 90 days after the end of the fiscal year. Action(s) taken or planned on the finding: Agreed. The Agent concurs with the finding and the auditor's recommendation. The Corporation will ensure future deposits to the residual receipts account are made within 90 days after the end of the fiscal year.
View Audit 361711 Questioned Costs: $1
Statement of Condition #2023-001: At March 31, 2023, the Corporation's reserve for replacement accounts were underfunded. Recommendation: The Agent should transfer $10,840 from the respective operating accounts to the reserve for replacements accounts. The Agent should make all required deposits to ...
Statement of Condition #2023-001: At March 31, 2023, the Corporation's reserve for replacement accounts were underfunded. Recommendation: The Agent should transfer $10,840 from the respective operating accounts to the reserve for replacements accounts. The Agent should make all required deposits to the reserve for replacements accounts. Action(s) taken or planned on the finding: Agreed. The Agent concurs with the finding and the auditor's recommendation. The Corporation made the $3,490 required transfer for REDI IV and the $7,350 deposit to REDI III.
View Audit 361711 Questioned Costs: $1
2023-004 Public Housing Waiting List Tenant Selection – RF (2022-006) In October of 2022 there was no waiting list in the Housing Management Software, there was not a handwritten waitlist that could be located. Staff entered all applications that were located into the software by date and time and w...
2023-004 Public Housing Waiting List Tenant Selection – RF (2022-006) In October of 2022 there was no waiting list in the Housing Management Software, there was not a handwritten waitlist that could be located. Staff entered all applications that were located into the software by date and time and with preferences that are in the out-of-date Admissions and Occupancy Policy and Administrative Plan. Documentation was submitted to the San Antonio Field Office in September of 2023 to show the waitlist and the families that have been selected in order of the waitlist or removed at the request of the family.
2023-003 Rent Reasonableness - RF (2022-005) In November of 2022, the Housing Authority started using a Rent Reasonableness form that compares the unit in question to two other units of the same type with similar amenities and age. If the unit in question is a Tax Credit property the Housing Authori...
2023-003 Rent Reasonableness - RF (2022-005) In November of 2022, the Housing Authority started using a Rent Reasonableness form that compares the unit in question to two other units of the same type with similar amenities and age. If the unit in question is a Tax Credit property the Housing Authority uses the unit's most currently rented, listed on the back of The Request for Tenancy Approval form, provided by the landlord to ensure the rent paid for assisted units is not more than unassisted units.
2023-002 Utilities Allowance Calculation – RF (2022-004) In June of 2022 new utility allowance schedules were adopted by the board, however the new schedule was not entered into the Housing Management Software. With annuals starting in November the new utility allowance schedule has been adhered.
2023-002 Utilities Allowance Calculation – RF (2022-004) In June of 2022 new utility allowance schedules were adopted by the board, however the new schedule was not entered into the Housing Management Software. With annuals starting in November the new utility allowance schedule has been adhered.
2023-001 Housing Quality Standards Inspection/HQS Enforcement - RF (2022-003) The staff performs initial lease up inspections and does not enter into a HAP Contract until the unit passes inspection. As each household comes up for annual examination a Housing Quality Standards inspection is being sch...
2023-001 Housing Quality Standards Inspection/HQS Enforcement - RF (2022-003) The staff performs initial lease up inspections and does not enter into a HAP Contract until the unit passes inspection. As each household comes up for annual examination a Housing Quality Standards inspection is being scheduled. Two attempts to schedule are made. If the family fails to set-up the inspection or allow inspection a 30-day notice of termination of assistance is sent to the family. Currently every unit is being inspected as they come up for annual re-examination. Currently the Administrative Plan requires annual inspections, not Biennial.
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The recommendations are included in the new grants policy. The City Manager shall review and approve it for implementation by September 2025. Planned Implementation Date:...
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The recommendations are included in the new grants policy. The City Manager shall review and approve it for implementation by September 2025. Planned Implementation Date: September 2025 Responsible Person(s): City Manager
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation and has implemented hiring for temporary work assignments in order to facilitate update. Corrective Action Plan: The HR and payroll software will be updated by the City by December 2025. Planned ...
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation and has implemented hiring for temporary work assignments in order to facilitate update. Corrective Action Plan: The HR and payroll software will be updated by the City by December 2025. Planned Implementation Date: December 2025 Responsible Person(s): City Manager
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The City Controller’s Office drafted a grants policy that is currently under review by City Management. Community development staff will ensure a succession plan is in pl...
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The City Controller’s Office drafted a grants policy that is currently under review by City Management. Community development staff will ensure a succession plan is in place for any staff turnover and for report preparation compliance. Planned Implementation Date: September 2025 Responsible Person(s): City Manager, City Controller, and Community Development Director
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