Finding Number 2025-001 – Special Tests and Provisions (Rent Reasonableness) Corrective Action: What we've already been doing to correct the issue LifeWire has strengthened oversight within Services by consolidating the Services and Rapid Rehousing programs under a single Director, creating clearer ...
Finding Number 2025-001 – Special Tests and Provisions (Rent Reasonableness) Corrective Action: What we've already been doing to correct the issue LifeWire has strengthened oversight within Services by consolidating the Services and Rapid Rehousing programs under a single Director, creating clearer accountability and consistency in implementation. Additionally, we have expanded our approval workflow to include multiple levels of review: Advocate → Manager → Director → Finance. This structured, multi-tiered review process increases oversight and enhances our ability to identify and address issues related to rent reasonableness documentation prior to payment. As part of this enhanced workflow, we require that internal audit practices occur at each level of approval, ensuring that rent reasonableness and comparable unit analysis documentation is reviewed for completeness, accuracy, and timeliness — and that review and approval occur prior to tenant move-in — before advancing to the next stage. At each level, reviewers will audit a minimum of 5% of files or 5 files per month, whichever is greater. What else we are putting in place LifeWire will continue to provide comprehensive training for all Services staff, including advocates, managers, and directors, focused on rent reasonableness requirements and the timing of comparable unit analysis completion and review. The Services Director is responsible for delivering and overseeing this training. This training will address the specific requirements outlined in 24 CFR §578.49 and §578.51 and reinforce expectations that documentation is completed, reviewed, andapproved prior to tenant move-in. All staff will be required to formally acknowledge completion ofthe training and their understanding of the updated requirements. Responsible Staff: Olivia Montgomery •Advocates (initial preparation of rent reasonableness and comparable unit analysisdocumentation) •Services Managers (first-level supervisory review and approval prior to move-in) •Services Director (program oversight and secondary review) •Executive Director (internal audit of Services Director approvals) •Finance Director / Finance Department (final review, approval, and payment oversight) Anticipated Completion Date: Enhancements are currently in progress, with full implementation and demonstrated compliance expected by Q3 2026.