Finding Text
S3800-010: Finding Reference Number
2024-002 (Significant Deficiency)
S3800-011: Program Information
Federal Program: Supportive Housing for Persons with Disabilities – Section 811
Federal Agency: Department of Housing and Urban Development
Assistance Listing #: 14.181
Pass-through Entity: None
Federal Award Identification Number and Year: N/A
Type of Compliance Finding: N – Special Tests and Provisions
S3800-015: Type of Finding
Federal Awards
S3800-016: Finding Resolution Status
Unresolved
S3800-017: Information on Universe Population Size
N/A
S3800-018: Sample Size Information
N/A
S3800-019: Identification of Repeat Finding and Finding Reference Number
2023-002 and 2022-002
S3800-020: Criteria
Per HUD Handbook 4381.5, REV-2, CHG-2, Management Agents of insured and assisted multifamily housing projects are required by HUD administrative guidelines to have a HUD approved Project Owner's / Management Agent’s Certification for Multifamily Housing Projects for very low-income persons with disabilities (Form 9839-B).
S3800-030: Statement of Condition
During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted that the Organization did not have a HUD approved Form 9839-B; the last effective date was August 31, 2014.
S3800-032: Cause
Form 9839-B expired in 2014 and the Organization failed to obtain an approved HUD Form 9839-B since then. The Organization submitted a request for approval of Form 9839-B to HUD in March 2023, however HUD requested additional documentation from the Organization regarding the operation and management of the property before granting approval. The additional documentation (a Management Agreement) and an updated HUD Form 9839-B request was submitted to HUD in October 2024; however, approval has not been granted by HUD as of the audit report date.
S3800-033: Effect or Potential Effect
Charges for management fees for the fiscal year were not authorized.
S3800-035: Auditor Non-Compliance Code:
J – Unauthorized management fee
S3800-040: Questioned Costs
$10,918
S3800-045: Reporting Views of Responsible Officials
The Organization agreed with this finding.
S3800-050: Context
The Organization is required to have all of its necessary forms and licenses current and up to date.
S3800-080: Recommendation
The Organization should establish a process to ensure they have obtained all required HUD approved forms. Additionally, the Organization should ask HUD to retrospectively approve Form 9839-B effective September 1, 2014. In March 2023, the Organization submitted a request for approval of Form 9839-B to HUD, however HUD requested additional documentation from the Organization regarding the operation and management of the property before granting approval. The additional documentation (a Management Agreement) and an updated Form 9839-B request was submitted to HUD in October 2024; however, approval has not been granted by HUD to-date.
S3800-090: Auditor’s Summary of the Auditee’s Comments on the Findings and Recommendations
Auditee agreed with our recommendation.
S3800-130: Response Indicator
Agree
S3800-140: Completion Date or Proposed Completion Date
July 31, 2025
S3800-150: Response
See Corrective Action Plan