Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856
Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client.
Explanation of disagreement with audit finding: There ...
Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856
Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client.
Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
Action taken in response to finding:
HOC’s third-party management agent, Pratum Companies, will ensure that all site staff with access to files complete the "Intro to Affordable Housing" training hosted by Pratum Compliance within the next 60 days. Pratum will also mandate that Regional Managers conduct random quarterly reviews of move-in files and annual recertifications. Furthermore, Regional Compliance Managers will perform spot checks and file reviews throughout the year.
Currently, every move-in file is reviewed by Pratum’s corporate Compliance team for program compliance, with Community Managers conducting an initial review before submission to the compliance team for final approval.
Pratum will ensure that each recertification packet includes a completed application, documentation of income, assets, expenses, and an executed recertification checklist. Additionally, Pratum will generate and send reminder letters at 120, 90, 60, and 30 days to all households to minimize late annual recertifications.
The Pratum Regional Managers and the Vice President of Operations will provide oversight and conduct weekly check-ins with the team to assess progress and completion of tasks. Regional Property Managers will review all corrective actions to ensure accuracy. A tracking spreadsheet will be maintained and reviewed during these weekly check-ins. This information will also be shared with the HOC compliance team during the monthly compliance and operations meetings to ensure alignment and transparency.
HOC’s Property Management Division now has a Compliance Manager who has updated the internal review process to mandate that all new move-ins and annual recertifications include a completed application, documentation of income, assets, expenses, and an executed recertification checklist.
The HOC compliance team will focus on conducting site visits for the Project Based Rental Assisted properties following the same guidelines used for the annual financial audit. The goal is to perform a 100% file review for properties with 25 or less units and a 50% file review for properties with more than 25 units.
The Compliance team will continue to conduct bi-monthly quality control reviews for the HOC managed properties, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively.
Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC.
Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions outlined above and is committed to correcting all specific discrepancies by March 31, 2025. The HOC compliance team will start the site visits in January 2025 and will review files from the start of the fiscal year. The PM Division has begun the updated internal review process outlined in the corrective action and has committed to correcting the discrepancies by November 30, 2024.