Finding Text
2024-001 Incomplete Transfer of Waitlist Information: Internal Control Weakness
Impacting HUD Compliance
Program Name/Assistance Listing Title: Supportive Elderly Housing - Section 202
Federal Assistance Listing No: 14.157
Federal Agency: U.S. Department of Housing and Urban Development
Type of Finding: Federal Award Finding
Compliance Requirements: Eligibility
Population Size and Sample Size Information: Out of total 37 tenants, 5 samples were
selected.
Criteria: HUD regulations states the following:
a. 24 CFR 891.410 (a). Owners shall maintain a written, chronological waiting list showing
the name, race, gender, ethnicity, and date of each person applying for the program.
b. HUD Occupancy Handbook 4350.3 REV-1 (Chapter 4: Waiting List and Tenant
Selection): Owners must develop a method to maintain documentation of the waiting list
composition, application status, and actions taken.
c. Compliance Supplement May 2024 : Owners must document that participants selected
from the waitlist met the preference criteria and were selected according to the admission
policies in the administrative plan. (24 CFR section 891.410)
d. 24 CFR 982.204: Except for special admissions, participants must be selected from the
PHA waiting list. The PHA must select participants from the waiting list in accordance
with admission policies in the PHA Administrative Plan. The PHA must maintain
information that permits the PHA to select participants from the waiting list in accordance
with the PHA admission policies. The waiting list must contain the following information
for each applicant listed:
(1) Applicant name;
(2) Family unit size (number of bedrooms for which family qualifies under PHA occupancy
standards);
(3) Date and time of application;
(4) Qualification for any local preference;
(5) Racial or ethnic designation of the head of household.
Condition: During eligibility testing, we were unable to verify compliance with HUD regulations
requiring selection from the waiting list in accordance with the administrative plan (24 CFR
section 891.410 and 24 CFR 982.204). The waitlist application dates generated from the Project’s
software reflect the initial data load from RealPage to Fortress and did not include essential waitlist
notes. This lack of documentation prevented us from verifying that tenant selection adhered to
HUD requirements and selected from waiting list in correct order.
Cause of Condition: The issue occurred due to an incomplete data transfer during the migration
from RealPage to Fortress. Internal controls over the data migration process were insufficient to
ensure that all required information, such as waitlist notes, was successfully transferred.
Potential Effect of Condition:
Noncompliance with HUD regulations for maintaining an accurate and chronological
waitlist.
Inability to demonstrate compliance with tenant selection requirements, which may result
in findings of noncompliance, questioned costs, or penalties.
Increased risk of unfair or improper tenant selection due to incomplete records.
Questioned Costs: No questioned costs are identified at this time, as the issue primarily concerns
documentation and internal controls rather than direct financial mismanagement.
Reporting Views of Responsible Officials: The Organization agrees with the findings and
recommendations and will adhere to the corrective action plan.
Context: The incomplete waitlist data impacts all units under the project where tenant selection
relies on the waitlist. This issue arose during the migration from RealPage to Fortress and was
discovered during eligibility testing for compliance with HUD regulations.
Recommendation:
Implement a process to review and verify the accuracy and completeness of data during
system migrations, including waitlist information and notes.
Reconstruct missing waitlist data by reviewing available source records, if feasible.
Develop and document a written policy for waitlist maintenance and data integrity to
ensure ongoing compliance with HUD regulations.
Management Response: Management is currently conducting a comprehensive review of the
process to ensure alignment with compliance requirements and identify areas for improvement.